Judgment

BHAGWATI, J.:- The dispute in this appeal by certificate relates to two items of expenditure incurred by the assessee during the assessment . year 1956-57 for which the relevant accounting year was the year ending on 30th September, 1955. The assessee is a private limited company carrying on business of manufacture and sale of crystal sugar in a factory situated in Pilibhit in the State of Uttar Pradesh. In the year 1952-53, a dam was constructed by the State of Uttar Pradesh at a place called Deoni and a road Deoni Dam-Majhala was constructed connecting the Deoni Dam with Majhala. It seems that the Collector requested the assessee to make some contribution towards the construction of the Deoni Dam and the Deoni Dam - Majhala Road and pursuant to this request of the Collector, the assessee contributed a sum of Rs. 22,332/- during the accounting year ending 30th September, 1955. The assessee also contributed a sum of Rs. 50,000/- to the State of Uttar Pradesh during the same accounting year towards meeting the cost of construction of roads in the area around its factory under a Sugar-cane Development Scheme promoted by the Uttar Pradesh Government as part of the Second Five