JUDGMENT S.C. Manchanda, J. - This is a case stated under Sec. 24 (2) of the U.P. Agricultural Income Tax Act (hereinafter referred to as the Act). The question referred is: "Whether the amount claimed by the assessee as expenses of management and miscellaneous expenses detailed above can be allowed as expenses of cultivation under Sec. 6(2) (b) (iv)." 2. The assessee is a sugarcane factory with an attached sugarcane farm. The assessee opted to be assessed under Sec. 6 (2) (b) of the Act and claimed several deductions. It was allowed all the expenses shown on sugarcane cultivation, country crop cultivation, irrigation, maintenance, tractors, employment and maintenance of cattle. The assessee, however, was not allowed the following expenses :- Senior Staff Establishment .......................... Rs. 3,180 Indian Establishment ................................... Rs. 4,021 15 3 Indian Menial Staff ....................................... Rs. 6,825 6 - Travelling Expenses .................................... Rs. 832 6 3 Staff Allowance................................................ Rs. 207 7 6 Garden Maintenance ................................... Rs. 2,062 2 3 Motor Car Maintenance ............................... Rs. 360 - - Lighting Plant Expenses.................................. Rs. 1,844 11 - Firm Contribution to Provident Fund................ Rs. 574 1 - Agency Allowance............................................ Rs. 1,800 - - The assessee had shown certain other expenses as miscellaneous expenses. They too were disallowed. They were as follows :- Subscription and Periodicals ....................... Rs. 159 - - Postage and Telegrams................................... Rs. 189 5 - Printing and Stationery ................................ Rs. 79 14 - Medicines and Medicals................................... Rs. 1,529 3 8 Sundries........................................................... Rs. 2,833 3 8 3. The management expenses were disallowed by the assessing authority as well as by the Commissioner on appeal for the reason that the assessee had not furnished detailed charts showing how these expenses were incurred and there was only half-hearted compliance therewith. The Commissioner had asked for these charts in connection with "costs of cultivation" as sufficient details were not given and it could not be ascertained as to the number of persons who were being employed or paid for this particular purpose. The aforesaid claim was disallowed and the claim was placed on the assessee for having failed to place all his cards on the table. The aforesaid claim was disallowed and the claim was placed on the assessee for having failed to place all his cards on the table. The Agricultural Income Tax Board agreed with the Commissioner that the necessary details had not been furnished and in addition held that the aforesaid expenses claimed by the assessee could not strictly be said "expenses incurred in raising the crop or making it fit for market." The aforesaid two questions have been referred for the opinion of this Court. 4. Mr. Chowdhary learned counsel for the assessee relied upon a decision given by a Bench of this Court in United Provinces Sugar Co., Ltd. v. The Agricultural Income Tax Commissioner, ITR No. 366 of 1953, D/d. 11.5.1956. In that case it was held that in the case of a big farm where some kind of central management and staff would be required the expenditure incurred thereon could be taken to be expenditure incurred for the raising of the crops. It was noticed that "income" had not been defined in the Act and "agricultural income", therefore, could not be given a restricted meaning and the quantum of the income could not be arrived at without taking into consideration the disbursements. It was also held that the maintenance of a motor lorry, a motor car, furniture and cycles were necessary for the proper supervision and transport of sugarcane etc. to the factory in the interest of efficiency and similarly provident fund was considered to be a part of the salary of the employees and, therefore an allowable expenditure in the raising of the crops. At the time when this decision was given there was, at least, under the Income Tax Act, a considerable divergence of opinion between the various High Courts in India as to what constitutes "agricultural purposes" and "agricultural income." The Supreme Court in Commissioner of Income Tax, West Bengal v. Raja Binoy Kumar Sahas Roy, 1957 (32) ITR 466 , after a review of the entire case law overruled several decisions and approving others laid down, at page 476 :- "..............."agricultural income" has been defined in the Constitution itself in Article 366(1) to mean agricultural income as defined for the purposes of enactments relating to Indian income-tax and there is a definition of "agricultural income" to be found in Sec. 2(1) of the Indian Income-Tax Act. We have, therefore, got to look to the terms of the definition itself and construe the same regardless of any other consideration." "It is interesting to note that all throughout these cases runs the central idea of either tillage of the land or sowing of seeds or planting or similar work on the land which invests the operation with the characteristic of agricultural operations and whenever that central idea is fulfilled there is the user of land for agricultural purposes and the income derived therefrom becomes agricultural income." (P. 484-485). "......it is pertinent, therefore, to enquire what is the connotation of the term "agriculture". As we have noted above, the primary sense in which the term agriculture is understood is agar-field and culture-cultivation, i.e., the cultivation of the field and if the term is understood only in that sense agriculture would be restricted only to cultivation of the land in the strict sense of the term meaning thereby, tilling of the land sowing of the seeds, planting and similar operations on the land. They would be the basic operations and would require the expenditure of human skill and labour upon the land itself. There are however other operations which have got to be resorted to by the agriculturist and which are absolutely necessary for the purpose of effectively raising the produce from the land. They are operations to be performed after the produce sprouts from the land, e.g., weeding, digging the soil around the growth, removal of undesirable under growths and all operations which foster the growth and preserve the same and not only from insects and pests but also from depredation from outside, tending, pruning, cutting harvesting, and rendering the produce fit for the market. The latter would (?) all be agricultural operations when taken in conjunction with the basic operations above described, and it would be futile to urge that they are not agricultural operations at all. But even though these subsequent operations may be assimilated to agricultural operations, when they are in conjunction with these basic operations could it be said that even though they are divorced from these basic operations they would nevertheless enjoy the characteristic of agricultural operations? But even though these subsequent operations may be assimilated to agricultural operations, when they are in conjunction with these basic operations could it be said that even though they are divorced from these basic operations they would nevertheless enjoy the characteristic of agricultural operations? Can one eliminate these basic operations altogether and say that even if these basic operations are not performed in a given case the mere performance of these subsequent operations would be tantamount to the performance of agricultural operations on the land so as to constitute the income derived by the assessee therefrom agricultural income within the definition of that term? "We are of opinion that the mere performance of these subsequent operations on the products of the land, where such products have not been raised on the land by the performance of the basic operations which we have described above would not be enough to characterise them as agricultural operations. In order to invest them with the character of agricultural operations, these subsequent operations must necessarily be in conjunction with and continuation of the basic operations which are the effective cause of the products being raised from the land. It is only if the products are raised from the land by the performance of these basic operations that the subsequent operations attach themselves to the products of the land and acquire the characteristic of agricultural operations. The cultivation of the land does not comprise merely of raising the products of the land in the narrower sense of the term like tilling of the land, sowing of the seeds, planting, and similar work done on the land but also includes the subsequent operations set out above all of which operations, basic as well as subsequent, form one integrated activity of the agriculturist and the term "agriculture" has got to be understood as connoting this integrated activity of the agriculturist. One cannot dissociate the basic operations, from the subsequent operations and say that the subsequent operations even though they are divorced from the basic operations can constitute operations by themselves." (Page 507 to 509). ................. "We are, however, of opinion that the mere fact that an activity has some connection with or is in some way dependent on land is not sufficient to bring it within the scope of the term and such extension of the term "agriculture" is unwar ranted. ................. "We are, however, of opinion that the mere fact that an activity has some connection with or is in some way dependent on land is not sufficient to bring it within the scope of the term and such extension of the term "agriculture" is unwar ranted. The term "agriculture" cannot be dissociated from the primary significance thereof which is that of cultivation of the land and even though it can be extended in the manner we have stated before both in regard to the process of agriculture and the products which are raised upon the land, there is no warrant at all for extending it to all activities which have relation to the land or are in any way connected with the land. The use of the word agriculture in regard to such activities would certainly be a distortion of the term. "A critical examination of the definition of "agricultural income" as given in Sec. 2(1) of the Indian Income Tax Act and the relevant provisions of the several Agricultural Income Tax Acts of the various States also lends support to this position. In the first instance, it is defined as rent or revenue derived from land which is used for agricultural purposes; and it is next defined as income derived from such land by agriculture or by the activities described in clauses (ii) and (iii) of Sec. 2 (1) (b) of the Act. These activities are postulated to be performed by the cultivator or receiver of rent-in-kind of such land in regard to the products raised or received by him. Which necessarily means the produce raised on the land either by himself or by the actual cultivator of the land who pays such rent-in-kind to him. If produce raised or received by the cultivator or receiver of rent-in-kind is thus made the subject-matter of clauses (ii) and (iii) in Sec. 2 (1) (b) of the Act, the term"agriculture" used in clause (i) of Sec. 2 (1) (b) must also be similarly restricted to the performance of the basic operations on the land and there is no scope for reading the term "agriculture" in the still wider sense indicated above." (P. 510). 5. 5. From the above it follows that the unreported decision relied upon can no longer be said to lay down good law as it undoubtedly gave the extended and wider meaning to the word agriculture and expenses pertaining to the raising of the crops and this the Supreme Court has disapproved. That apart, the facts of the present case are clearly distinguishable and it is well settled that a decision is only an authority for the particular set of facts upon which it is pronounced. 6. It follows from the aforesaid Supreme Court decision that only such expenses can be said to be incurred for the raising of crops from which agricultural income is derived which can be directly or effectively related to or connected with the performance of the primary and secondary operations on the land itself. Expenses which certain to the business side of the organisation as opposed to the expenses attributable to the actual raising of the crops will not fall within the ambit of the expenses allowable under Sec. 6 (2) (b) (iv) of the Act. There must be an approximate and not merely a remote or far-fetched connection between the expenditure incurred and the agricultural income which is to be taxed. Therefore, the expenses for the tilling of the land, sowing of seeds, planting and similar operations on the land itself would be allowable as these would constitute the basic agricultural operations. The expenses incurred on secondary operations performed after the produce has sprouted from the land, for example, digging, weeding, pruning, tending, cutting, harvesting and making the produce fit for market would also be allowable but not expenses of directors, provident fund contributions and such like as they would not directly but, if at all, very remotely be related to the raising of the crop. All such services by the directors and the staff maintained at Kanpur may be necessary or even valuable for the business part of the organisation but such expenses will not be allowable under the express provisions of Sec. 6 (2) (b) (iv) of the Act. 7. In Bacha F. Gazdar v. Commissioner of Income Tax, Bombay, 1955 (27) ITR 1 , it was held by the Supreme Court that in order to constitute agricultural income the income must be derived directly from agriculture and not merely remotely therefrom. 7. In Bacha F. Gazdar v. Commissioner of Income Tax, Bombay, 1955 (27) ITR 1 , it was held by the Supreme Court that in order to constitute agricultural income the income must be derived directly from agriculture and not merely remotely therefrom. In that case it was claimed that dividend income from a tea company was partly agricultural and therefore that part was exempt from taxation under the Income Tax Act. It was held that the connection of the dividend income, though from tea was a very remote one and, therefore, could not be treated as agricultural income exempt under the Income Tax Act. 8. The definition of agricultural income given in the U.P. Agricultural Income Tax Act, 1948 is given in Sec. 2(1) as:- "Agricultural income has the same meaning as is assigned to it in the Indian Income Tax Act 1922 . . ." 9. Therefore, there is no escape for the assessee, even under the Agricultural Income Tax Act from the restricted meaning given to "agricultural income" by the Supreme Court in the decision rendered under the Income Tax Act. The position under the two acts being the same it necessarily follows that if only income from primary or secondary operations performed upon the land alone is agricultural income and not other remotely connected operations, then the expenses allowable in order to determine the agricultural income must also be those which have an intimate connection with the primary and secondary operations performed upon the land itself. 10. That apart, Sec. 6 (2) (b) of the Act leave little or no room for enlarging the scope of the expenses that can be deducted. The relevant portion of Sec. 6 (2) (b) reads: "The income shall be the gross produce or sale, of all the produce of the land subject to the following deductions: (iv) The expenses incurred in the previous year in raising the crop from which the agricultural income is derived, in making it fit for market and in transporting it to market including the maintenance or hire of agricultural implements and cattle required for these purposes." Therefore, under sub-clause (v) only three kinds of expenses are allowable. They are :- (1) The expenses for raising of the crop. (2) The expenses for making it fit for market; and (3) Transporting it to the market. 11. They are :- (1) The expenses for raising of the crop. (2) The expenses for making it fit for market; and (3) Transporting it to the market. 11. It has also been provided that the expenses will include the maintenance or hire of agricultural implements and the cattle required for the aforesaid three purposes. It is manifest that when the legislature had been at such great pains to specify the exact kind of expenditure, which will be allowed, there can be no room for enlarging the scope thereof. No discretion has been left to the assessing authorities to allow any other kind of expenditure. There is even no residuary clause as there is in Sec. 10 (2) (xv) of the Income Tax Act where expenditure which is wholly and exclusively laid down for the purpose of carrying on the business may be allowed. The only residuary clause under the Act is (xiii), but there also no discretion is given to the assessing authorities and is conditional upon "such other deductions as may be prescribed." 12. The order of the Commissioner shows that all expenses relating to the raising of crops, making it fit for taking it to the market and transporting it to market have already been allowed. It is only the management expenses and the miscellaneous expenses such as for subscription for periodicals, postage and telegrams, printing and stationery, medicines and sundries which have been disallowed. Those expenses cannot possibly be said to be directly or approximately connected with the raising of the crops, nor for making them fit for market or for transporting them to the market. These are expenses which at best can only be said to be, loosely speaking, remotely connected with the business side of marketing its produce and have no connection with the raising of the crops. 13. In any event, there is no material on the record to connect the impugned expenditure with the raising of the crops or for making it fit and transport it to the market. 13. In any event, there is no material on the record to connect the impugned expenditure with the raising of the crops or for making it fit and transport it to the market. It is well settled that the burden of proving the necessary facts in order to claim a deduction of expenses lies on the assessee; See Commissioner of Income Tax v. Calcutta Agency Ltd.,1951 (19) ITR p. 191 S.C. It is of little or no avail for the assessee to say that the assessing authorities did not ask it to correlate or connect the expenses with the raising of the crops or transporting them to the market. It was the assessee who was claiming the deductions and the burden was upon him to lay the necessary foundation for the claim and to connect the establishment expenses of the Head Office at Kanpur with the actual raising of the crops. This was not done nor was it possible and, therefore, the assessee had relied upon generalisations in order to support its claim. Generalizations in the matter of claiming allowances will not do and cannot take the place of proof. 14. For the reasons given above the question is answered in the negative and against the assessee. The assessee will pay the costs of this reference which we assess at Rs. 200/-. Counsel's fee is also assessed at Rs. 200/-.