1995 (6) TMI 4

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.... is as to whether the expenditure incurred on the payment of gratuity by the company can be deductible for the purpose of section 5(e) of the Tamil Nadu Agricultural Income-tax Act, 1955 (hereinafter referred to as "the Act"). Section 5(e) of the Act is as follows: "5. Computation of agricultural income.----The agricultural income of a person shall be computed after making the following dedu....

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....ses incurred in the previous year on maintenance and repairs in respect of any capital asset which was purchased or constructed for the benefit of the land from which the agricultural income is derived ; (e) any expenditure incurred in the previous year (not being in the nature of capital expenditure or personal expenses of the assessee) laid out or expended wholly and exclusively for the purpo....

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.... for doing agricultural work. Therefore, it is an expenditure incurred wholly and exclusively for the purpose of the land as without utilising the service of the employees the land cannot be put to the intended use. The tea and cardamom estate in question cannot be maintained and produce cannot be obtained and agricultural income from the land cannot be obtained without employing workmen and staff....