SETHURAMAN J.

These two revision petitions have been filed under s. 54(1) of the Tamil Nadu Agrl. I.T. Act, 1955, to revise the orders of the Agricultural Income-tax Appellate Tribunal, Madras, dated 22nd March, 1975, and 1st July, 1976, respectively for the assessment years 1973-74 and 1974-75. The assessee is a public limited company owning an estate measuring 1, 028.65 acres in Sheveroy Hills. In the estate coffee is grown. For the assessment year 1973-74, the assessee filed a return of loss of Rs. 52, 289. The assessing authority found some inadmissible deductions having been claimed and after adjusting them the loss disappeared and an income of Rs. 32, 828 was assessed to tax. In computing the income, the Agrl. ITO had not allowed deduction of Rs. 1, 60, 233 representing the estimated claim for gratuity. The assessee, in fact, did not make the claim for a deduction of the sum of Rs. 1, 60, 233 at the time of the filing, of the return, nor had it debited the said amount in the profit and loss account or in the profit and loss appropriation account. In the balance-sheet for the year ending on 30th June, 1973, the staff pension and gratuity reserve stood at Rs. 7, 125