1961 (7) TMI 5

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....appeal with special leave has been filed by the Salar Jung Estate Committee through its Executive Secretary against the judgment and order of the High Court of Hyderabad dated April 15, 1955, in respect of the assessment of the appellant for the year 1357 Fasli. The respondent is the Commissioner of Income-tax, Hyderabad Division. The following questions were referred by the Income-tax Tribunal....

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.... appellant had claimed a deduction of Rs. 2,65,226-11-10 under clauses (a) and (b) of section 14(5). The Appellate Tribunal allowed half of it as expenditure. The High Court differed from the Tribunal and disallowed the deduction on the ground that no sanad or order of the grantor enjoining such expenditure had been produced in the case. In the connected appeals,we have quoted an extract from the ....

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....dants, who attended upon the sanadholder in his capacity as jagirdar. These were not his private servants, who have been separately shown in section (C), expenses under which were disallowed. Though we were referred to some of the items in section (C), no serious attempt was made to bring them within clause (a) of section 14(5). The assessee, however, contended that the expenditure in section (B) ....

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.... and the other half, as for administration. Such a rough and ready test is not possible in this case. The three sections have been made advisedly. Section (A) deals with expenditure over the army ; section (B), with expenditure over the official retinue and section (C), with expenses in the palace. Even if section (C) contains some items of expenditure on administration, such items are incapable o....