Judgment:
V.S. Sirpurkar, J.
1. The revision is against the order of the Tamil Nadu Agricultural Income-tax Appellate Tribunal, Chennai (hereinafter referred to as 'the Tribunal'), whereby the Tribunal has confirmed the two orders of the earlier authorities. The first claim was regarding Rs. 4,00,000, wherein the appellant claimed that they have paid a sum of Rs. 4,00,000 for the management and technical service charges to one other company named United Nilgiris Tea Estate Company Ltd. The second claim was about the expenditure incurred for repairs to the buildings to the tune of Rs. 24,14,397.54. On both the counts, the courts below have found against the petitioner.
2. In so far as the first payment of Rs. 4,00,000 is concerned, that was the amount claimed by the assessee on the ground that they had given the task of supervision and management of the tea estate to one United Nilgiris Tea Estate Company Ltd. All the courts have rejected this claim on the ground that there was not even a single agreement or document suggesting that the said United Nilgiris Tea Estate Company had in any way agreed to perform this task for the consideration of Rs. 4,00,000.
3. Mr. P.P.S. Janardhana Raja, learned counsel for the applicant, earnestly argued that in the earlier years the amount of Rs. 3,00,000 was allowed by the same authorities on this very count. That can hardly be a reason to allow this amount this year also. We do not know as to what was the document produced at that time. Be that as it may. We do not find any perversity or illegality in the order of the Tribunal, which has gone into the facts. It was claimed by Mr. Janardhana Raja that a letter was produced by the management of the assessee-company. That letter was disbelieved as it was a unilateral letter on behalf of the assessee-company. We do not find any fault with it. Accordingly, we confirm the finding that the assessee-company failed to prove that it actually paid Rs. 4,00,000 for the management and technical services. That apart, there is hardly any evidence on record to suggest the account of the services provided by the United Nilgiris Tea Estate Company. There is no evidence led on that behalf.
4. In so far as the second payment of Rs. 24,14,397.54 is concerned, very strangely this amount was never reflected in the monthly returns. On the other hand, the amount reflecting the repairs was merely Rs. 62,368.32. It is really strange that the amount should have jumped to Rs. 24,14,397.54 in their final returns.
5. Hence, in our opinion, the authorities have not committed any mistake in rejecting these two claims. We confirm the order of the Tribunal and dismissthe revision.