1991 (3) TMI 10

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....ng the net taxable income for the said year, disallowed some items of expenses. The order of the assessing authority disallowing some items of expenses was questioned before the appellate authority who allowed the appeal in part, but maintained the disallowance, in respect of certain items of expenses. The petitioner preferred further appeal to the Agricultural Income-tax Appellate Tribunal and the Tribunal allowed certain more items of expenses in full while some claims were allowed in part. We are relieved of the need to deal with the items which were disallowed or partly allowed by the assessing authority, the appellate authority and the Tribunal, as the present revision case before us is confined to the disallowance sustained by the App....

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....s of the account and when that is the position and the Tribunal had accepted it as a principle to allow the deduction for mess expenses, it does not stand to reason as to why the entire expenses should not have been allowed and the deduction should have been confined only to Rs. 3,000. The position would have been entirely different if certain items in the expenditure included under "mess expenses" were either disallowed or some reason was given to doubt the correctness of the mess expenses submitted through the accounts. That is not the position in this case. We find from a comparative statement furnished by learned counsel for the petitioner before us that in the year 1977-78, the entire mess expenses claimed which had been disallowed by ....

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....ose of the land. " A bare reading of the clause shows that the deduction would be permissible of any expenditure incurred in the previous year laid out or expended " wholly and exclusively for the purpose of the land. " How could the advertisement charges be treated to be an expenditure incurred wholly and exclusively for the purpose of the land ". The Tribunal noticed the claim of the petitioner-assessee on account of the advertisement charges and found that the expenditure incurred on that account Was mainly incurred as " donations to various organisations ". It was found on the basis of the materials on record by the Tribunal that such a donation was not connected with the agricultural income of the assessee. Nothing has been brought ....