1997 (8) TMI 13

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....in revision against the order of the Agricultural Income-tax Appellate Tribunal which has allowed the assessee to deduct the amount of interest paid from the interest received by it during the year 1981-82 even before considering the assessee's entitlement to the amount of interest that it can properly claim as deduction under section 5(k) of the Tamil Nadu Agricultural Income-tax Act, 1955. Th....

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....s it stood at the relevant time imposed a ceiling on the interest deductible under that provision. It is not open to the assessee to enlarge that amount by claiming set off of the interest earned against the interest paid and claiming the benefit under section 5(k) of the Act in respect of the balance. The computation of income has first to be made and the computation of items of expenditure to....

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....hat the deduction of the interest income from the interest paid was in order. While making that observation, the court did not take into consideration the limitation of the amount of interest that can be claimed as deduction under section 5(k) of the Act. We are unable to regard that judgment as having laid down the proposition that, despite the ceiling on the amount of interest deductible under s....