Judgment :- RAJU, J. The assessee is the petitioner before this court. For theassessment year 1980-81, the petitioner appears to have filed a return under the Tamil Nadu Agricultural Income-tax Act, 1955 (hereinafter referred to as "the Act"), and the rules made thereunder, disclosing a net agricultural income of Rs. 28, 72, 934. The Agricultural Income-tax Officer-II, Nagercoil, on going through the accounts and considering the various claims for deduction, determined the net assessable income at Rs. 34, 35, 514 and the total tax due for the said assessment year from the assessee at Rs. 22, 33, 084.10 Aggrieved against the action of the assessing authority in disallowing certain deductions claimed, an appeal has been preferred before the Assistant Commissioner of Agricultural Income-tax, Nagercoil. The first appellate authority partly allowed the appeal by sustaining deductions claimed on certain accounts and in other respects dismissed the appeal. The assessee pursued the matter on further appeal before the Tamil Nadu Agricultural Income-tax Appellate Tribunal, Madras. Before the Tribunal, deductions have been claimed under nearly 14 items. The Tribunal also partly allowed the appeal before it and rejected the appeal in other respects. Aggrieved, the above revision has been filed before this court. The revision petition filed is directed against the disallowance sustained by the Tribunal in respect of the following four items. Rs 1. Corporation tax 2, 000 2. Advertisement expenses 8, 028 3. Subscription to clubs 1, 745 4. Legal expenses 7, 250 Mr. R. Gangadharan, learned counsel for the petitioner, vehemently contended that the disallowance of the items referred to above by the authorities below from deduction claimed is contrary to law and that the claim of the assessee in respect of the above items also should have been allowed as against section 5(e) of the Act. Learned counsel sought to place reliance upon the decision of the Bombay High Court in Godavari Sugar Mills Ltd. (No. 1) v. CIT. On the other hand, Mrs. Chitra Venkataraman, the learned Additional Government Pleader (Taxes), contended that, having regard to the nature of the expenditure, their purport and object, no exception could be taken to the disallowance of the claim of the petitioner by the authorities below and that the provisions of section 5(e) do not enure to the rescue of the petitioner to justify the deduction claimed. On behalf of the Revenue, the ratio of an unreported decision of this court in New Ambadi Estates (P.)Ltd. v. State of Tamil Nadu, represented by the Commissioner of Agrl. Income-tax (T. C. Nos. 711 to 713 of 198 1, dated February 19, 199 1), relating to the very case of the petitioner with regard to earlier years, was pressed into service. We have carefully considered the submissions of learned counsel appearing on either side. In our view, the authorities below cannot be said to have committed any patent error of law nor could their approach, appreciation and findings be said to have been vitiated by any perversity of approach. Section 5(e) of the Act reads as thereunder, "any expenditure incurred in the previous year (not being in the nature of capital expenditure or personal expenses of the assessee) laid out or expended wholly and exclusively for the purpose of the land ;" Though the scope and purport of the above provision was construed many a time by this court, inasmuch as assessees who were dissatisfied with the disallowance of their claims before the authorities below often tried to justify their claim under the provision in question, considering the same to be their last resort, the same question is being often and relentlessly reiterated. Before adverting to the justifiability or otherwise of the claims made in the present case, it would be useful to refer to the scope and purport of the provision in question once again. Before justifying the claim for deduction under section 5(e) of the Act, an assessee is bound to substantiate that any expenditure in respect of a deduction has been incurred in the previous year, the same not being in the nature of capital expenditure or personal expenses of the assessee, wholly and exclusively for the purpose of the land. The phraseology "wholly and exclusively for the purpose of the land" was considered in juxtaposition with the phraseology used in some other sub-sections of section 5 such as "actually spent on the land from which the agricultural income is derived" and "in respect of" or "for the benefit of" land from which the agricultural income is derived. In so construing, it has been held by this court, vide Kil Kotagiri Tea and Coffee Estates Co. Ltd. v. Govt. In so construing, it has been held by this court, vide Kil Kotagiri Tea and Coffee Estates Co. Ltd. v. Govt. of Madras, that the expression "for the purpose of the land" is much wider in scope than the other expressions and that it may cover a wide range of expenses not necessarily incurred for deriving agricultural income. But at the same time, such judgments have repeatedly reiterated and emphasised the fact that notwithstanding the possible wide import of the expression, it should be substantiated to have the benefit of the said provision, that the expenditure in question has been expended wholly and exclusively for the purpose of the land, meaning thereby that the expenses in question should be shown to have been spent for the purpose of or in connection with the lands, though not directly having nexus to the agricultural income derived. Consequently, sufficient nexus between the expenses incurred and the land or the activities connected with the land should be substantiated. Hence, in our view, unless some nexus or relevance of the expenditure to the land or activities connected with the land is established, the assessee cannot claim the benefit of section 5(e) in respect of any and every expenditure incurredSo far as the items of deduction claimed by the petitioner before us are concerned, we are of the view that none of the said items of expenditure could be considered to be eligible for deduction under section 5(e) of the Act. Neither the Corporation tax said to have been paid with reference to the Administrative Office at Madras, nor the advertisement expenses or the subscription to clubs (Madras Club and Madras Gymkhana) could, even by any liberal construction given, be said to be satisfying the essential requisite that the expenditure in question has been wholly and exclusively incurred for the purpose of the land. The item of expenditure sought to be excluded under the pretext of legal expenses is nothing but the fee paid to the Registrar of Companies for the purpose of increasing the capital of the company and the connected expenditure therewith cannot also in our view be said to satisfy the vital requirement noticed by us supra to qualify the claim to be sustained under section 5(e) of the Act. The reliance sought to be placed on the decision of the Division Bench of the Bombay High Court, referred to by learned counsel for the petitioner, is wholly inappropriate for the issue before us. The decision of the Bombay High Court was in the context of the peculiar provisions contained under the Income-tax Act, 1961, and, therefore, cannot be pressed into service, without regard to the special language used in the Act under consideration before us. It may also be noticed for the sake of completeness that, in the unreported decision relied upon by the learned Additional Government Pleader, the Division Bench of this court held that tax paid under section 111 of the Madras City Municipal (Corporation) Act, being rates on profession, art or calling or business or appointment within the city of Madras, there is absolutely no relevance to the tax paid at Madras to the Corporation for the land and this claim for deduction need not be sustained under section 5(e) of the ActFor all the reasons stated above, in our view, the action of the authorities below and the conclusion of the Tribunal, disallowing the items of expenditure claimed for deduction in respect of items challenged before us, could not be said to suffer from any error of law warranting our interference. The above revision, therefore, fails and shall stand dismissed, but, in the circumstances of the case, there will be no order as to costs.