TMI Blog1997 (8) TMI 23X X X X Extracts X X X X X X X X Extracts X X X X ..... r of the Tribunal, which disallowed several amounts claimed by the assessee as deduction in the computation of agricultural income for the assessment year 1984-85. The amounts disallowed are Rs. 1,300 claimed as paid to workers, Rs. 170 said to be miscellaneous expenses, Rs. 3,420 said to be legal charges and court expenses, Rs. 1,906 claimed as refreshment charges, and a sum of Rs. 1,30,782.60 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ourt of facts. The finding recorded by it with regard to the unsustainability of all these claims, having regard to the fact that the same had not been substantiated by records, cannot be interfered with. The petitioner has contended that the Tribunal ought to have allowed the amount of Rs. 1,44,780.65, claimed as the amount paid as interest in its entirety. The Tribunal has restricted the deduc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... if they are otherwise within the scope of section 5(e). The Tribunal has also noticed the fact that the assessee's contentions before it were contradictory. The Tribunal has observed : "It was not submitted before us that the interest expenditure related to amounts borrowed for the purpose of the land covered by section 5(e) and the amount borrowed was not spent on the land in which event it c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... disallowed. In the grounds of appeal the assessee has contended that his capital has been wiped out and he has only accumulated losses and therefore interest payment should be regarded as falling under section 5(e). No such contention was put forth before the Tribunal or the authorities below. In any event, there is no material to substantiate any claim that interest was paid on borrowings effect ..... X X X X Extracts X X X X X X X X Extracts X X X X
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