Judgment :- 1. The Revenue is the petitioner in both these Original Petitions. The respondent in both the cases is the same assessee. The matter arises in connection with the assessment of the respondent to Agricultural Income-tax for the years 1975-76 and 1976-77. The assessee/respondent claimed the legal expenses incurred by it (classified under professional fee for taxation work) as an admissible expenditure in computing the agricultural income. The claim was negatived by the Assessing Authority. In the appeal, preferred by the assessee, the Deputy Commissioner (Appeals) allowed the claim. In second appeal, the Agricultural Income Tax Appellate Tribunal sustained the allowance ordered by the first appellate authority. Aggrieved by the decision of the Appellate Tribunal, the Revenue filed two reference applications under S.60(1) of the Agrl. Income-tax Act praying that the following two questions may be referred to this Court for decision: L Whether on the facts and in the circumstances of the case, was the Tribunal right in holding that the expenses incurred for the professional fee for the taxation work is allowable deduction under S.5 of the Agricultural Income-tax Act ? ii. Was not the decision of the High Court of Kerala reported in 115 ITR 624 distinguishable on facts and in law? The Appellate Tribunal held that no referable question of law arose as suggested by the Revenue. The applications were dismissed. In pursuance thereto, the Revenue has filed the above two Original Petitions under S.60(3) of the Agricultural Income Tax Act praying that this Court may be pleased to direct the Appellate Tribunal to refer the said two questions for the decision of this Court. 2. We heard counsel for the Revenue as also counsel for the assessee/ respondent. Counsel for the Revenue contended that the matter is covered by the decision of this Court in Commissioner of Agrl. Income Tax, Kerala v. Nilambur Rubber Co. Ltd. (1969) 71 ITR 686 and so in view of the said decision, the expenses incurred for preparation of the agricultural income-tax returns are not allowable in determining the assessable income under the Agricultural Income-tax Act. It was contended that reliance placed by the Appellate Tribunal in the decision reported in Commissioner of Agrl. Income-tax v. Malayalam Plantations Ltd. (1978) 115 ITR 624 -1978 KLT. It was contended that reliance placed by the Appellate Tribunal in the decision reported in Commissioner of Agrl. Income-tax v. Malayalam Plantations Ltd. (1978) 115 ITR 624 -1978 KLT. 600 and the decision of the Supreme court in Commissioner of Income-tax, West Bengal v. Birla Brothers P. Ltd. (1971) 82 ITR 166, is misplaced. The legal expenses incurred and classified under professional fee for taxation work is not an admissible deduction under S.50) of the Agricultural Income Tax Act. It was contended that this is not an expenditure laid out or expended wholly and exclusively for the purpose of deriving the agricultural Income. On the other hand; counsel for the assessee contended that the crucial words in S.50) of the Agrl. Income-tax Act are similar to S.10(2)(xv) of the Indian Income Tax Act, 1922 and the legal expenses incurred for taxation work is an admissible expenditure. It was argued that the legal expenses incurred for representation before the Investigation Commission was held to be a permissible expenditure under S.10(2)(xv) of the Income-tax Act, 1922, by the Supreme Court in Birla Cotton Spinning & Weaving Mills Ltd. case (1971) 82 ITR 166 and so in view of the said decision, the legal expenses incurred even for taxation work is an admissible expenditure, under S.50) of the Agrl. Income-tax Act. 3. On hearing the rival contentions of the parties, we are of the view that the plea of the Revenue should fail. id Malayalam Plantation's case (1978) 115 ITR 624, this Court held that S.50) of the Agricultural Income Tax Act and S.10(2)(xv) of the Indian Income Tax Act, 1922 represent conceptions which are kindred though distinct. It was also hold that to confine S.50) to cover only those expenses which are directly and immediately relatable to the derivation of income will be to import limitations which are not there, either in the language or in the context, and to hold that what is contemplated is only "agricultural expenses" considered as an antithesis of "agricultural income." Once it is accepted that the language of S.50) of the AIT Act and that of S.10(2)(xv) of the Income-tax Act, 1922 are only kindred expressions, it cannot admit of any doubt that any expenditure laid out or expended, for the purpose of agricultural income will be a deductible expenditure. Indeed, in Birla Cotton Spinning And Weaving Mills Lid. Indeed, in Birla Cotton Spinning And Weaving Mills Lid. case (1971) 82 ITR 166 at p. 172, the Supreme Court held that if the assessee takes any steps for reducing its liability to tax which result in more funds being left for the purpose of carrying on the business, there is always a possibility of higher profits and this will be a permissible expenditure. 4. In the light of the decision in Malayalam Plantations' case (1978) 115 ITR 624 and the decision in Birla Cotton Spinning And Weaving Mills' case (1971) 82 ITR 166, we have to hold that any expenditure incurred in connection with the receipt of the agricultural income is a deductable expenditure. The decision in Malayalam Plantations' case was followed in ITR Nos. 63, 64 and 65 of 1978 and also in ITR Nos. 109 and 125 of 1977 and 107 and 50 of 1977. The question that arose for consideration in ITR Nos. 63, 64 and 65 of 1978 was whether on facts in the circumstances of the case, the expenses incurred in filing appeal, revision, reference application, etc. (claimed as legal charges) are allowable deduction in computing the Agrl. Income under S.50) of the AIT Act. This Court held that the matter is covered by the decision in Malayalam Plantations' case (1978) 115 ITR 6241978 KLT 600. So also, in ITR Nos. 109 and 125 of 1977, the question that arose for consideration was whether the legal expenses and travelling expenses incurred in connection with taxation matters were allowable deductions. Following the decision in Malayalam Plantations' case (1978) 115 ITR 624, this Court held that they are permissible deductions. The decisions in ITR Nos. 107 and 50 of 1977 are also to the same effect. 5. In the light of the decisions of this Court in ITR Nos. 63, 64 and 65 of 1978 and also in ITR Nos. 109 and 125 of 1977 and 107 and 50 of 1977, it is too late in the day to contend that the legal expenses incurred and classified under professional fee for taxation work is not an admissible expenditure in computing the Agrl, income under S.50) of the AIT Act. We are of the view that the Appellate Tribunal was justified in holding that the legal expenses incurred for taxation work is an admissible expenditure. We are of the view that the Appellate Tribunal was justified in holding that the legal expenses incurred for taxation work is an admissible expenditure. The Division Bench decision of this Court in Malayalam Plantations' case (1978) 115 ITR 624 was followed in the later unreported decisions mentioned above. 6. In the light of the above reasoning, we hold that no referable question of law arises for consideration from the order of the Appellate Tribunal. 7. There is no merit in these two Original Petitions. They are dismissed. Dismissed.