JUDGMENT Mookerjee, J. - These are two references under sec. 63 (1) of the Bengal Agricultural income tax Act (Bengal Act IV of 1944). Moved by the Commissioner of Agricultural income tax, West Bengal, a question has been formulated by the Tribunal in the same terms in both the cases only the respective period of assessment is different in the two cases. The question for decision is whether in respect of the selami or premium received in the previous year the assessee is entitled to any allowance for cost of collection under sec. 6 (7) of the Bengal Agricultural income tax Act, 1944. Under sec. 6 of the Bengal Agricultural income tax Act tax is payable in respect of rent and revenue, included by an assessee in his total agricultural income as received in the previous year. In view of the decision in Birendra Kishore Manikya v. Secretary of State for India ILR 48 Cal 766 (1921), it is now the common case of both the parties that premium received on settlement of agricultural lands is "rent or revenue" derived from land and is assessable to agricultural income tax. 2. Out of the amount received as agricultural income the assessee is entitled to certain deductions or allowances as specified in sec. 6 of the Act. Allowance is claimed in the present case under cl. (7) of sec. 6. The relevant portion of sec. 6 along with cl. (7) is in the following terms:-- Sec 6-Agricultural Income tax shall be payable by an assessee under the head "agricultural income from rents or revenue" in respect of all rent and revenue.................derived from land referred to in Sub-clause (a) of Clause (1) of sec. 8 included in his total agricultural income and received in the previous year, subject to the following allowances, namely................... (7) in respect of the cost of collection of such rent or revenue including the coat of maintenance of any katchari or other capital assets and any expenses of litigation, a sum equal to fifteen per centum of the total amount of rent or revenue which accrued to him in the previous year in respect of the land from which such rent or revenue is derived. 3. On behalf of the assessing authority it is contended by the learned Advocate-General that the allowance allowable under cl. 3. On behalf of the assessing authority it is contended by the learned Advocate-General that the allowance allowable under cl. (7) can be claimed on such rent or revenue which accrued to the assessee in the previous year and the use of the word "accrue" signifies that only such items of income as grow and are received at recurring periods, are to be taken into account. In the first paragraph of sec. 6 the taxable income is on the basis of what was "received in the previous year," but in the case of the allowance allowable such allowance is to be calculated only on that portion of the income which had "accrued to him in the previous year." Accrual is, according to the revenue authorities, that which signifies continuous growing or flowing and not that which is received only once. Or, in other words, the rent which is paid by the tenant accrues from year to year but in the case of selami received after settlement there is no continuity but only one payment, as a result of a solitary transaction. 4. Reference is made to the definition of the word "accrue" as appearing in Murray's Oxford Dictionary which is Arise or spring as a natural growth, especially interest. 5. Special emphasis is laid on the idea of natural growth which, it is urged, signifies a process of evolution and excludes that which arises or springs only once. The definition as given by Murray does not in our opinion limit the use of the term merely to recurring payments. The various examples given under this particular definition by Murray do not support this contention. As an instance of the use of this word Blackstone (Comm. 11 269) is quoted which runs as follows:-- The forfeiture for such alienation accrued in the first place to the immediate lord of the fee 6. The interpretation, which is now attempted to be put on the definition as given by Murray would exclude this particular example which is cited under this definition. 7. In Wharton's Law Dictionary "accrue" is stated to stand for "to grow to" or "to arise." In Bouvier's Law Dictionary "accrue" is "to grow to; to be added to." In the Century Dictionary the definition given is "to arise in due course". In Webster's Dictionary "accrue" means "to increase, to augment. 8. 7. In Wharton's Law Dictionary "accrue" is stated to stand for "to grow to" or "to arise." In Bouvier's Law Dictionary "accrue" is "to grow to; to be added to." In the Century Dictionary the definition given is "to arise in due course". In Webster's Dictionary "accrue" means "to increase, to augment. 8. When applied to a cause of action "accrue" means to commence, to come into existence or to become a present enforceable demand. When used in connection with the accrual of title, a title accrues when the instrument creating it or the fact constituting it first becomes operative. The definitions and instances cited above unmistakeably indicate that the word "accrue" is used not merely in cases where a process of evolution continues in future but also when something arises as from a particular transaction at a particular moment. 9. Even when considering the implication of the word "accrue" in connection with rent Patterson, J., observed in Slack v. Sharpe. 8 Ad I.E. 3(sic)6 (878);s.c. 112 E.R. 876 (1879) "The question is merely when the rent accrued. Rent accrues when it becomes due and at no other time." The fact that rent continues to accrue due in future is not taken into consideration for determining what accrues due during a particular period or within a particular date. 10. The word "received" appearing in the first paragraph of sec. 6 may not have the significance as the word "accrue" in cl. (7) under sec. 6 but we are not called upon to express any opinion as to the implications of the word "receive" which according to the ordinary dictionary sense means and involves an actual receipt. Sometimes and in certain context there is a definite difference between the amount "received" and "receivable" but whether that difference is to be found in the first paragraph of sec. 6 or not it does not fall to be decided in the present case. We are concerned with the interpretation of the word "accrue" in cl. (7). As indicated above, this term is not limited according to the ordinary dictionary meaning to a process of evolution continuing in future but it is quite clear that it conveys the same idea as the verb "to arise" and such is evidently the sense in which the word is used in cl. (7). (7). As indicated above, this term is not limited according to the ordinary dictionary meaning to a process of evolution continuing in future but it is quite clear that it conveys the same idea as the verb "to arise" and such is evidently the sense in which the word is used in cl. (7). It may be pointed out that while considering whether premium or selami on settlement of waste land is agricultural income or not, Mookerjee, A.C.J., indicated in Birendra Kishore Manikya v. Secretary of State far India ILR 48 Cal 766 (1921) "there can be little doubt that when a lease is granted the amount fixed for periodical payment is not independent of the amount paid in lump sum as premium. The capitalised value of the sum periodically payable, taken along with the premium, constitutes in the aggregate the consideration for the grant; so that the larger the one element, the smaller the other." From this point of view we must hold that the premium paid for the settlement of waste lands or abandoned holdings may reasonably be recorded as "rent or revenue" derived from land, within the meaning of that expression as used in the definition "agricultural income" in sec. 2 (I) (a)" of the Income Tax Act. 11. So the incidence of payment of the rent and of the selami is in no way different, one becoming payable periodically on due dates, and the other being payable either in a lump on a fixed date or in instalments, as the case may be. 12. It is a cardinal rule of interpretation that one should in the first instance interpret the section and the words used therein unless there is any doubt or if other portions of the Act do not stand in the way of such an interpretation--and in such cases one has to look at the whole Act and examine not merely a particular section or a part of a section. In the case now before us there is no provision in the Act which runs counter to the interpretation of the word "accrue" as indicated already. Further, the total amount received as premium or selami is considered to be rent or revenue under the first paragraph of sec. 6 of the Act as assessable to tax, and unless there be a very clear provision limiting the operation of cl. Further, the total amount received as premium or selami is considered to be rent or revenue under the first paragraph of sec. 6 of the Act as assessable to tax, and unless there be a very clear provision limiting the operation of cl. (7) to only a portion of such "rent or revenue," the legislature must be deemed to have made no difference between the provision in the exemption clause and that of the charging clause. 13. The learned Advocate-General had referred to the fact that the costs for collection of a lump sum paid as selami cannot be on the same basis as the cost of collection of a recurring amount, viz., rent. The question whether the cost of collection is high or low does not fall to be considered in interpreting cl. (7) of sec. 6 of the Act. The simple reason is that irrespective of the amount which may be spent by a particular assessee for collection, etc., the statute has fixed 15 per cent. in all ordinary cases. The cases of a zemindar who lets out in patni his entire zemindary and that of another land-holder who has got to collect rent from a large number of tenants holding small plots are all treated similarly. It is, therefore, not on the basis of actual costs of collection that we have to decide whether it is the intention of the legislature to bring within cl. (7) of sec. 6 a lump sum payment received during the previous year. 14. At best, it may be argued that the question whether such an allowance is allowable on selami received is not altogether free from doubt. If there be any doubt, or if there be two alternative interpretations possible, a taxing statute must be interpreted in favour of the assessee and against the Revenue Authorities. 15. In our opinion, therefore, in respect of the selami which accrued to the assessee during the previous year allowance is to be allowed as under cl. (7) of sec. 6 of the Act. The question referred must be answered in the affirmative. The assessee is entitled to costs of this hearing--hearing-fee being assessed at 10 gold mohurs in each of the two cases. Das, J. I agree.