SANGHAMESHWAR COFFEE ESTATES LIMITED Vs. STATE OF KARNATAKA

JUDGEMENT

(1.) M/s. Attikhan (Biligiri) Limited, Bangalore ("Attikhan"), a public limited company incorporated under the Companies Act, 1956, inter alia, owned an extensive coffee estates measuring about 427 acres in Chamarajnagar Taluk of Mysore District and by an order made by this court on June 19, 1981, that company had merged in another public limited company called Sanghameshwar Coffee Estates Limited, Bangalore ("Sanghameshwar"). As transferee of all the assets and liabilities of Attikhan, Sanghameshwar has filed these revision petitions before this court. We will, however, treat them as the assessee.

(2.) ON the coffee estate owned by it, Attikhan had constructed and maintained a Hindu temple employing the services of a poojari or a priest and had incurred pooja expenses from time to time.

(3.) SRI K. P. Kumar, learned advocate of King and Partridge, has appeared for the assessee. SRI S. Rajendra Babu, learned Government Advocate, has appeared for the Revenue. Both sides, in support of their respective contentions, have relied on a large number of rulings and we will refer to them at the appropriate stage.