https://www.taxtmi.com/caselaws?id=39467 Rule 8A(d) requiring the Tea Board certificate in Form No. 5 to be furnished with the return of income is directory, not mandatory, when claimed as evidence for development allowance under section 33A. The certificate is evidentiary in character and intended to help verify whether the statutory conditions are met. Because timely issuance may be outside the assessee's control, insisting on simultaneous filing would frustrate the allowance's object and cause unjust forfeiture. Late production of the certificate before assessment is completed does not by itself defeat the claim. en-us Mon, 05 Jan 1976 00:00:00 +0530 Fri, 16 Apr 2010 16:05:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39467 Rule 8A(d) requiring the Tea Board certificate in Form No. 5 to be furnished with the return of income is directory, not mandatory, when claimed as evidence for development allowance under section 33A. The certificate is evidentiary in character and intended to help verify whether the statutory conditions are met. Because timely issuance may be outside the assessee's control, insisting on simultaneous filing would frustrate the allowance's object and cause unjust forfeiture. Late production of the certificate before assessment is completed does not by itself defeat the claim. Case-Laws Income Tax Mon, 05 Jan 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39467