Judgment :- Radhakrishnan, J. The only question that has been raised for consideration in this case reads as follows: Whether on the facts and in the circumstances of the case the Tribunal was right in holding that the profits of eligible business computed in accordance with the requirements of parts II and III of Schedule VI to the Companies Act, 1956 should be reduced by income from coffee sales, arecanut sales, rent receipts, interest and subsidy from Tea Board for the purpose of computing the deduction allowable under sub-clause (ii) of Cl. (b) of section 32AB(1)? Assessee in his return claimed deduction of Rs.37,02,849/- under section 32AB on the basis of the entire income of the previous year. Assessing officer allowed deduction on an amount calculated without including rent, interest and sundry receipts. Commissioner (Appeals) agreed with the assessing officer that the relief was to be worked out on the profits of eligible business or profession as contemplated in section 32AB and that rent, interest and sundry receipts did not form part of the profits of the eligible business. Tribunal concurring with the view of the Commissioner (Appeals) held that the assessing officer was justified in excluding the receipts by way of rent, interest and sundry receipts for the purpose of computing the deduction under section 32AB. While deciding the case tribunal placed reliance on the decision in Kil Kotagiri Tea & Coffee Estates Co. Ltd. (ITA) No.1017/Coch/90 dated 17-10-1996). 2. Counsel appearing for the assessee submitted that the assessee was engaged in the “eligible business” as defined in section 32AB and so the entire income computed in accordance with para 2 and 3 of the Sixth Schedule to the Companies Act had to be considered for working out the deduction. Further it is also pointed out that the assessee had credited the assessment, interest and the sundry income in the profit and loss account for the business only and therefore there is no justification for excluding those receipts for the purpose of deduction under section 32AB. Counsel also placed reliance on the Division Bench decision of this court in CIT v. Kil Kothagiri Tea & Coffee Estate Co. Ltd. (2005) 273 ITR 278. 3. Counsel also placed reliance on the Division Bench decision of this court in CIT v. Kil Kothagiri Tea & Coffee Estate Co. Ltd. (2005) 273 ITR 278. 3. Counsel appearing for the revenue on the other hand contended that Section 32AB allows deduction of a sum equal to 20% of the profits of the eligible business or profession only and that rent, interest and sundry receipts are had profit of the business carried to by the assessee. Counsel submitted, even though assessee had credited the above receipts in the profit and loss amount that did not mean the they are the profits of any business. 4. We find force in the contention of the counsel appearing for the revenue. However, we notice the Division Bench in the above mentioned decision has expressed the view that while computing the profits of eligible business for the purpose of section 32AB of the Income tax Act, 1961, income from all sources except those which are exempted has to be taken into consideration and thus, every income which is computed under the Companies Act has to be taken into consideration and therefore there is no justification in excluding those receipts of income for the purpose of deduction under section 32AB. 5. We find it difficult to accept the reasoning of the Division Bench. Under such circumstances we are inclined to refer the matter to a Larger Bench for an authoritative pronouncement. We notice that while deciding the case of Kil Kothagiri Tea & Coffee Estate Co. Ltd. The Bench had referred to the decision of the Supreme Court in Apollo Tyres Ltd. V. CIT. (2002 255 ITR 273 and the Bench decision of the Madras High Court in CIT v. Tamil Nadu Mercantile Bank Ltd. (2002) 255 ITR 205.