Judgment :- BAKTHAVATSALAM, J. This revision petition is filed against the orders of the Agricultural Income-tax Appellate Tribunal, Madras, disallowing two items claimed by the petitioner as allowable deductions under the Tamil Nadu Agricultural Income-tax Act, 1955 ("T.N.A.I.T.", in short). The petitioner claims deduction of Rs. 2, 400 and Rs. 2, 056 under the head "Labour welfare expenses" in respect of payments made for conducting dramas and another deduction of Rs. 2, 83, 742.86 in respect of payment of interest on the loans borrowed and spent on immature plants. Though the Tribunal allowed in part the claim regarding interest on loans borrowed and spent on immature plants, it rejected the claim of the petitioner under the head "Labour welfare expenses" in respect of payments made for conducting dramas. Earlier, the Assessing Officer disallowed the claim under the head "Labour welfare expenses", but gave relief under the head "payment of interest on loans borrowed and spent on immature plants" to the extent of Rs. 1, 38, 780.05. On appeal, as stated earlier, the Tribunal disposed of the claim of the petitioner in part regarding interest on loans while rejecting the payment made for conducting dramas. The petitioner is before us questioning the two items disallowed by the Tribunal With regard to the interest paid on the amounts borrowed for maintaining immature coffee plants, a Division Bench of this court in the case of the very same assessee, had held that it is an allowable deduction under section 5(e) of the Tamil Nadu Agricultural Income-tax Act, 1955, and the case is reported in Puthutotam Estates (1943) Ltd. v. State of Tamil Nadu. Following that, another Division Bench of this court has applied the same ratio in a case reported in Sakthi Estates v. State of Tamil Nadu. In view of the categorical decisions of the two Division Benches of this court, we do not think the learned Additional Government Pleader (Taxes) can have any valid defence on this aspect of the matter. So the order of the Tribunal, in so far as it has denied the benefit of section 5(e) of the Tamil Nadu Agricultural Income-tax Act to the petitioner is concerned, has got to be set asideWith regard to the expenses incurred for payments made for conducting dramas in the sums of Rs. 2, 400 and Rs. So the order of the Tribunal, in so far as it has denied the benefit of section 5(e) of the Tamil Nadu Agricultural Income-tax Act to the petitioner is concerned, has got to be set asideWith regard to the expenses incurred for payments made for conducting dramas in the sums of Rs. 2, 400 and Rs. 2, 056, the Tribunal gave a finding that the connection with the agricultural activity, if anything, is indirect and remote. In our view, the conclusion reached by the Tribunal is unassailable. Mr. Srinivasamoorthy, learned counsel for the petitioner/ assessee relied upon the decision of the apex court in Sassoon J. David and Co. Pvt. Ltd. v. CIT, with regard to the construction of the expression "wholly and exclusively" used in section 10(2)(xv) of the Indian Income-tax Act, 1922. In construing the provisions of the said section of the Indian Income-tax Act, 1922, the apex court of the land has held that the expression "wholly and exclusively" used in section 10(2)(xv) of the Indian Income-tax Act, 1922, does not mean "necessarily". In our view, the question before us is with regard to the construction of the expression "wholly and exclusively for the purposes of the land"(emphasis supplied) used in section 5(e) of the Tamil Nadu Agricultural Income-tax Act, 1955. A Division Bench of this court, while construing the expression "for the purpose of the land" in the case of Kil Kotagiri Tea and Coffee Estates Co. Ltd. v. Govt. of Madras, at page 168, observed as follows: "These decisions show that the expression 'for the purpose of the land' covers a wide range of expenses taking in not only the expenses incurred actually for deriving agricultural income, but also expenses which are not directly incurred for deriving agricultural income but expended in connection with the lands which do not have any relationship to the agricultural income derived in the previous year." If the above principle is borne in mind, we have no hesitation to hold that the Tribunal is right in coming to the conclusion that the deduction was claimed in connection with the expenses which do not have any relationship to the agricultural income derived in the previous year. The very same view has been taken by us in an unreported case in New Ambadi Estates (Pvt.) Ltd. v. State of Tamil Nadu (since reported in (T. C. No. 154 of 1983, dated June 29, 1992) when construing the scope of section 5(e) of the Tamil Nadu Agricultural Income tax Act, 1955. Hence, we do not find any merit in the contention of learned counsel for the petitioner/assessee with regard to this decisionIn the result, the revision petition is allowed in part and we hold that the assessee is entitled to claim deduction under section 5(e) of the Tamil Nadu Agricultural Income-tax Act towards payment of interest on the loans borrowed and spent on immature plants to the tune of Rs.3, 83, 742.86. No costs.