TEEKOY RUBBERS (INDIA) LTD. Vs. STATE OF KERALA

JUDGEMENT

(1.) This is a reference by the Agricultural Income-tax Appellate Tribunal, Trivandrum, under section 60(1) of the Agricultural Income-tax Act, 1950. The assessee is the Teekoy Rubbers (India) Limited, Palai. The assessment year concerned is 1960-61; and the accounting period, the twelve months ended on March 31, 1960. The question referred is :

(2.) Section 5 of the Agricultural Income-tax Act, 1950, provides that the agricultural income of a person shall be computed after making the deductions mentioned in that section. One of the deductions specified reads as follows :

(3.) In Gordon Woodroffe Leather Manufacturing Company v. Commissioner of Income-tax, the Supreme Court formulated the test to be applied as follows :