Judgment :- R. JAYASIMHA BABU, J. In this revision the assessee has come up with the contention that any amount of interest paid on the outstanding borrowings is to be deducted from the agricultural income as an expenditure laid out or expended wholly and exclusively for the purpose of the land under section 5(e) of the Tamil Nadu Agricultural Income-tax Act, 1955. The assessment year in question is 1979-80. The amount claimed as deduction on that ground was Rs. 3, 56, 891.46. The Assistant Commissioner allocated this interest to the purpose referred to in sections 5(k) and 5(e) of the Act. He allowed in accordance with the second proviso under section 5(k) of the Act after calculating nine per cent. of 25 per cent. of the agricultural income for the year, the income for the year being Rs. 14.08, 573. The Assessing Officer had allowed that sum and the Assistant Commissioner, on appeal, affirmed it. The Assistant Commissioner also allowed a sum of Rs. 1, 78, 882.02 as interest under section 5(e) of the Act. He arrived at that figure of Rs. 1, 78, 882 after apportioning the expenditure for the year of assessment, for the purposes specified under sections 5(e) and 5(k). lie found that this sum of Rs. 1, 78, 882 represents the interest paid on the borrowings failing outside section 5(k) and within the ambit of section 5(e). He, therefore, allowed the appeal regarding the sum of Rs. 1, 78, 882 which sum had been disallowed by the Assessing Officer. The disallowance of a part of the amount under section 5(k) of the Act was on account of the ceiling imposed by the proviso to that section The Tribunal has affirmed the order of the Assistant Commissioner. The Tribunal, in the course of its order, noted that the borrowings in respect of which the interest liability had been incurred were made in the year 1972-73. It noted the submission made for the assessee before the Tribunal as under "According to the appellants, there were five borrowings in the year 1972-73 and the interest was being paid for that. It may not be possible to locate the purpose for which the amount borrowed was spent at that time. In some instances, it was contended that the agriculturists and the plantation owners borrow money for different purposes, but pool tip in the bank account and draw it for expenditure. It may not be possible to locate the purpose for which the amount borrowed was spent at that time. In some instances, it was contended that the agriculturists and the plantation owners borrow money for different purposes, but pool tip in the bank account and draw it for expenditure. So it would not be possible to decide as to which amount had been paid for which purpose and to assess as to whether it would come under section 5(e) or 5(k)" * The Tribunal, after noting this submission of the assessee, went on to hold as under "In view of that difficulty, the only other mode is to categorise the expenditure under the two heads clearly as to whether it would come under section 5(e) or 5(k) and allocate the interest in proportion to the particular head to the total expenditure . . . The details of expenditure which would come under sections 5(k) and 5(e) have been provided by the assessee as seen from the statement filed before the Assistant Commissioner." * Learned counsel for the assessee contended that the Tribunal was in error in holding that the allocation of expenditure incurred in the year of assessment was applicable to the earlier years when the borrowing was actually effected, and that the entire amount of the interest paid on the arrears of the unpaid loan should be allowed under section 5(e) of the Act Section 5(k) of the Act deals with interest paid in the previous year on any amount borrowed and actually spent oil the land from which the agricultural income is derived. This section does not specify that the borrowing must have been effected in the previous year. On the borrowings made at any point of time prior to or during the previous year, if the amount so borrowed had been spent on the land from which the agricultural income is derived, the interest paid on such borrowing can only be considered under section 5(k). This section also does not require that the amounts borrowed should have been spent on the land in the previous year. The amount borrowed in the earlier years might have been spent in those earlier years on the land from which the agricultural income is derived. This section also does not require that the amounts borrowed should have been spent on the land in the previous year. The amount borrowed in the earlier years might have been spent in those earlier years on the land from which the agricultural income is derived. If the interest liability in respect of such borrowings had been incurred in the previous year, any claim for deduction of interest so paid can only be considered under section 5(k) and not under section 5(e)If the amount borrowed by the assessee had been pooled into a common bank account, it is not possible to spell out the source from which amounts were spent in different years for specific purposes. It is in that background that the Assistant Commissioner adopted the ratio between the expenditure falling under section 5(k) and the expenditure falling under section 5(e) for the assessment year, as the ratio to be adopted for the borrowings effected in the earlier years and remaining unpaid in the previous year. After arriving at the amount of interest paid on that part of the loan on earlier years, which remained outstanding and which could be regarded as loans obtained and spent on the land from which the agricultural income is derived, the deduction was allowed to the extent permissible under section 5(k) of the Act. The amount which could not be considered under section 5(k) barring the amount disallowed, has been allowed under section 5(e). We do not find any illegality in the method so adopted The assessing authority had of necessity to adopt a workable method for determining the interest paid on the outstanding loan allowable as a deduction and allocating the same under sections 5(k) and 5(e), as the assessee did not furnish all the necessary particulars regarding the manner in which the moneys had been expended in the earlier years from out of the loans still outstanding. The proportion in which expenditure was incurred in the previous year has therefore been adopted as the basis for allocating the amount of interest to be allowed as a deduction, under sections 5(e) and 5(k) even though the borrowings were in the earlier years. It is not open to an assessee to obtain a larger benefit by merely asserting that the Assessing Officer should allow his claim, without furnishing all the relevant information. It is not open to an assessee to obtain a larger benefit by merely asserting that the Assessing Officer should allow his claim, without furnishing all the relevant information. Since the particulars required to be furnished were not furnished, it was open to the authority to adopt the method which was not unfair or illegal. We are satisfied that the method adopted cannot be regarded as violative of any provision of law and the method adopted is fairWe do not see any merit in this revision and, therefore, the revision is dismissed.