Judgment :- JANARTHANAM, J. The assessee - Yuvaraj International, Tirupur, is a manufacturer and exporter of hosiery clothes. For the assessment year 1981-82, it filed a return admitting an income of Rs. 1, 51, 260. In arriving at the income, the applicant claimed weighted deduction under section 35B of the Income-tax Act, 1961 (for short "the Act"), on the following, Rs (a) Foreign travel expenses 57, 882 (b) Agency commission 2, 57, 219 (c) Interest commission and foreign bank charges 95, 450 Total 4, 10, 551 The Income-tax Officer, while completing the assessment under section 143(3) of the Act allowed weighted deduction in respect of foreign travel expenses to the extent of Rs. 45, 000 and disallowed the balance on the ground that the foreign travel extended beyond a period of 75 days as approved by the Reserve Bank of India. As respects the agency commission, the claim is found to be in order by the Income-tax Officer. He also disallowed the entire expenses of interest, etc., of Rs. 95, 450 as ineligible for weighted deduction. On appeal, the Commissioner of Income-tax (Appeals), Coimbatore, held that the entire expenses in respect of foreign travel is eligible for weighted deduction, but sustained the order of the Income-tax Officer in respect of other expenses on the ground that those expenses were not admissible under any of the provisions of section 35B(1)(b). Before the Commissioner of Income-tax (Appeals), the assessee raised an additional ground that the aggregate claim under section 35B should be Rs. 2, 61, 454 based on rule 6AA of the Income-tax Rules, 1962, which came into force from August 1, 1981. The Commissioner of Income-tax (Appeals) admitted fresh grounds, but rejected the contention on the ground that the benefit of rule 6AA is not available to the assessee for the assessment year in questionAggrieved, the assessee filed an appeal to the Tribunal. The Tribunal held that interest, etc., charges cannot be considered for weighted deduction for the assessment year, in question, in view of the fact that these expenses fall under section 35B(1)(b)(viii) of the Act, which was deleted with effect from April 1, 1981. As regards the applicability of rule 6AA for the assessment year in question, the Tribunal held that the rule cannot be said to be restrospective in operation and, therefore, cannot be applied for the assessment year in question. As regards the applicability of rule 6AA for the assessment year in question, the Tribunal held that the rule cannot be said to be restrospective in operation and, therefore, cannot be applied for the assessment year in question. On the above facts, the Tribunal referred the questions of law as below for the opinion of this court for the assessment year 1981-82, "1. Whether the Tribunal was right in holding that the assessee is not entitled to weighted deduction under section 35B in respect of interest, commission and foreign bank charges ? 2. Whether the Tribunal was right in holding that the assessee is not entitled to weighted deduction under section 35B to the extent of Rs. 2, 61, 454 being the correct claim made based on rule 6AA of the Income-tax Rules ? 3. Whether the Tribunal was right in holding that rule 6AA of the Income-tax Rules which came into effect on August 1, 1981, is not applicable to the assessment year 1981-82 ?" The arguments of Mr. K. Vaitheeswaran, learned counsel representing S. Subbaraya Aiyar, learned counsel appearing for the applicant and of Mrs. Chitra Venkataraman, learned junior standing counsel (Taxes), representing the Revenue were heard. Section 35B(1)(a) dealing with export markets development allowance provides that where an assessee, being a domestic company or a person (other than a company), who is resident in India, has incurred after February 29, 1968, but before March 1, 1983, whether directly or, in association with any other person, any expenditure (not being in the nature of capital expenditure or personal expenses of the assessee) referred to in clause (b), shall, subject to the provisions of this section, be allowed a deduction of a sum equal to one and one-third times the amount of such expenditure incurred during the previous yearThe proviso appended to the said sub-section prescribed that in respect of the expenditure incurred after February 28, 1973, but before April 1, 1978, by a domestic company, being a company in which the public are substantially interested, the provisions of this clause shall have effect as if for the words "one and one-third times", the words, "one and one-half times" had been substituted. The nature of the expenditure referred to in clause (a) is catalogued in clause (b). The nature of the expenditure referred to in clause (a) is catalogued in clause (b). The expenditure catalogued in clause (b) must be incurred wholly or exclusively under any one of the sub-clauses (i) to (ix) of clause (b) specified therein. Interest, commission and foreign bank charges to the tune of Rs. 95, 450 are sought to be claimed as the nature of the expenditure as had been provided by sub-clausle (iv) of clause (b), which is relatable to expenditure concerning maintenance outside India of a branch, office or agency for the promotion of the sale outside India of such goods, services or facilities. We are unable to comprehend as to how interest commission and foreign bank charges amounting to Rs. 95, 450 can if at all fall as an expenditure concerning maintenance outside India of a branch, office or agency for the promotion of the sale outside India of such goods, services or facilities. The nature of the expenditure speaks for itself and no further elucidation is necessary that such expenditure can if at all fall within sub-clause (iv) of clause (b). In this view of the matter, we are of the view that the Tribunal was rather right in holding that the assessee is not entitled to weighted deduction under section 35B in respect of interest, commission and foreign bank charges and this question is answered accordingly. The second question is relatable to weighted deduction claimed under section 35B(1)(b)(ix) to the extent of Rs. 2, 61, 454. The deduction under section 35B(1)(b)(ix) is relatable to expenditure concerning such other activities for the promotion of the sale outside India of such goods services or facilities as may be prescribedRule 6AA of the Income-tax Rules, 1962, explains the nature of other activities for the promotion of sale outside India of the goods, services or facilities as had been stated in sub-clause (ix) of clause (b) of sub-section (1) of section 35B. Rule 6AA of the Rules, which is relevant for the present purpose reads as under: "6AA. Rule 6AA of the Rules, which is relevant for the present purpose reads as under: "6AA. For the purposes of sub-clause (ix) of clause (b) of sub-section (1) of section 35B, other activities for the promotion of the sale outside India of the goods, services or facilities which the assessee deals in or provides in the course of his business shall be as follows, namely (a) conducting of pre-investment surveys or the preparation of feasibility studies or project reports Provided that the pre-investment surveys are conducted or the feasibility studies are made or the project reports are prepared on the request in writing made by the Central Government or a foreign party to whom such goods, services or facilities are likely to be sold or provided by the assessee; (b) maintenance outside India of a warehouse for the promotion of the sale outside India of such goods; (c) maintenance of a laboratory or other facilities for quality control or inspection of such goods. Provided that in a case where only part of the sale is made outside India, the amount of expenditure incurred on the maintenance of such laboratory, or, other facilities which shall qualify for deduction under clause. (a) of sub-section (1) of section 35B shall not exceed the amount which bears the same proportion as the value of the turnover in respect of such exports bears to the turnover of the business in respect of which the laboratory or other facilities are maintained; (d) purchase of foreign trade periodicals or journals related to the business of the assessee;(e) litigation outside India for the purposes of the protection of the business interests of the assessee or of trading activities relating to the goods, services or facilities which the assessee deals in or provides in the course of his business." The expenses claimed as deduction under section 35B(1)(b)(ix) to the extent of Rs. 2, 61, 454 is in the nature of general expenses, and definitely not of the nature of the expenses as falling within clauses (a) to (e) of rule 6AA of the Rules. Only such of those expenses as are falling under clauses (a) to (e) of rule 6AA of the Rules, can qualify for deduction under section 35B(1)(b)(ix) and not otherwise. The expenses to the tune of Rs. Only such of those expenses as are falling under clauses (a) to (e) of rule 6AA of the Rules, can qualify for deduction under section 35B(1)(b)(ix) and not otherwise. The expenses to the tune of Rs. 2, 61, 454 as already stated, being in the nature of general expenses and not falling under the category of expenses described under any one of the clauses (a) to (e) of rule 6AA cannot at all be expected to qualify for deduction under section 35B(1)(b)(ix). We are, therefore, of the view that the Tribunal was right in holding that the assessee is not entitled to weighted deduction under section 35B(1)(b)(ix) to the tune of Rs. 2, 61, 454 being in the nature of general expenses and this question is answered accordingly. As respects the third question also, we are of the view that the Tribunal was right in holding that rule 6AA of the Income-tax Rules, which came into effect on August 1, 1981, is not applicable to the assessment year. 1981-82. The reasons are rather obvious. The rule has come into force only on and from August 1, 1981, is not in retrospective operation with effect from April 1, 1981, the date of the commencement of the assessment year. Axiomatic a proposition of law it is, that a rule or a provision of a statute, which is in force on and from the date of the commencement of the assessment year alone is applicable to the assessment year in question and to put it otherwise, as the rule or statutory provision came into force subsequent to the day of commencement of the assessment year, such rule or statutory provision is, not at all applicable to the assessment year in questionNo decision for such a proposition is necessary and if any decision is needed even for such a proposition of law, we may quote here the decision emerging from a Division Bench of this court, in the case of CIT v. Palaniswamy, wherein their Lordships of this court expressed that though the subject of the charge of income-tax is the income of the previous year, the law to be applied is the law that is in force as on the first day of April of the assessment year, unless the law is changed. In this view of the matter, as we had already stated, the Tribunal is rather right in holding that rule 6AA of the Income-tax Rules, which came into effect on August 1, 1981, is not applicable to the assessment year 1981-82 and this question is answered accordingly. For the reasons as above, this tax case is dismissed. There shall, however, be no order as to costs, on the facts and in the circumstances of the case.