Development allowance under sec. 33A-Creation of reserve- Instruction regarding

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.... Sir,             Subject:  Development allowance under sec. 33A-Creation of reserve- Instruction regarding. Attention is invited to section 33A of the Income-tax Act, 1961, which provides for the grant of deduction by way of development allowance of a certain percentage of expenses incurred on planting of tea bushes on any land i....

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.... it is pointed out that the provisions of law require that the reserve should be equal to 75% of the "development allowance actually to be allowed". It is argued that since only 40% of the income of a tea company is chargeable to tax, the actual allowance on account of development allowance is only 40% of the amount calculated on the basis of specified percentage of the cost of planting tea bushes....