1990 (11) TMI 30

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..... fer the ordeal of a protracted proceeding until finally the claim that the said sum should be exempted from the agricultural income-tax has been upheld by the Agricultural Incometax Appellate Tribunal. The State, however, has not left the matter at that. It has come to this court. The Revenue's case has been noticed by the Tribunal in these words: " . . . The Revenue's case is that the legal exp .....

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..... . In order to preserve the title to the lands he had before sale, he incurred the expenses in the appeals preferred by the State. " Indeed, the State was responsible for the litigation that the assessee had to suffer up to the Supreme Court for establishing his title to the land with respect to which he was called upon to pay tax, so much so, that the said protracted proceedings caused a sale of .....

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..... wholly and exclusively for the purpose of his business and, therefore, allowable as deduction for the purpose of computing the profits for income-tax purposes. This ruling has to be applied to agricultural income as well. The impugned order, in our opinion, does not suffer from any illegality or impropriety. The same is, accordingly, confirmed. This tax revision case is dismissed. There will be n .....

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