The appellant then preferred a revision application to the High Court under section 54 1 of the Madras Plantations Agricultural Income Tax Act, 1955 Mad.
The assessment relates to the year 1955 56, the accounting year being the year ending March 31, 1955.
Of that area 235 acres were occupied by immature number bearing rubber trees and 270 acres had mature rubber trees.
V of 1955 .
Out of that area 85 acres were companyered by pepper, arecanut, paddy and companyonut cultivation while the rest, i.e., 505 acres, had rubber plantations upon it.
The Agricultural Income tax Tribunal held that the expenses incurred on the whole area under rubber plantations were deductible expenses and remanded the case for ascertaining the expenses incurred in forking and manuring of the number bearing and immature rubber grown areas also.
The respondent claimed from out of the income expenses relating to the maintenance and upkeep of immature number bearing rubber trees.
12 of 1957.
If anything, the words of the former Act are more favourable to the respondent.
The respondent who is the assessee owned an estate of 590 acres in South Malabar district, number in Kerala State.
290 292 of 1959, which was an assessment under the Travancore Cochin Act, we have decided the question of deductibility of sums expended for purposes of forking, manuring, etc.,
In Civil Appeals Nos.
The only difference is in the last few words.
In place of fir the purpose of the plantation in the former, the words for the purpose of deriving the agricultural income are used in the latter.
Kapur, J. This is an appeal by special leave against the judgment and order of the High Court of Kerala in Tax Revision No.
