1. The Agricultural Income tax Appellate Tribunal has made this reference under S.60 (1) of the Agricultural Income-tax Act, 1950 (hereinafter referred to as the Act). The year of assessment is 1962-63 and the question referred reads thus:

"Whether on the facts and in the circumstances of the case, the managing agency commission on rubber replanting subsidy is allowable expenditure."

During the relevant accounting period pertaining to the year of assessment, 1962-63, a sum of Rs. 50,388/-has been received as rubber replanting subsidy by the assessee company. The assessee company is engaged in the business of running a rubber estate. The company claimed 9 per cent of the amount of Rs. 50,388/-as an item of expenditure which they urged, should be deducted in computing its income for the purpose of taxation under the Act. This has been negatived.

2. It is not contended before us that this amount can be claimed as a deduction under any provision other than S.5 of the Agricultural Income-tax Act, 1950. The relevant sub-section is sub-section 0) which is in these terms:

"Computation of agricultural income:

The agricultural income of a person shall be computed after making the foll