Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additions do not increase tax.

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....Social forestry expenditure requires activity-based classification: costs of growing saplings through primary land operations are agricultural, while supervision of farmers' trees and coppice shoots without primary land operations are business or non-agricultural expenditure. Disallowance is therefore confined to the loss from agricultural sapling cultivation. For book-profit computation, only that restricted disallowed agricultural loss may be adjusted, rather than all amortised social forestry expenditure. Where normal-computation additions do not affect tax because liability is based on book profit, no tax is sought to be avoided and concealment penalty is not warranted. Penalty may nevertheless arise if concealed income increases book profit and the resulting minimum alternative tax.....