(1.) THUTTAPULLAM Estate is an assessee in the circle of the Agricultural Income-tax Officer, Coonoor. It is a registered firm. The firm consists of 13 partners.
(2.) T. Jayaraman (applicant in T.C. (R.) No. 887 of 1990), Jayalakshmi (applicant in T.C. (R.) No. 888 of 1990) and T. Sivapackim (applicant in T.C. (R) No. 889 of 1990) were partners in the said firm, apart from other erstwhile partners. All the partners of the said firm had no lands individually except the proportionate share of the land held by them in the said firm. The partners have no individual income from agriculture. However, the Agricultural Income-tax Officer, Coonoor, permitted the partners of the said firm to have the matter compounded under section 65(3) of the Tamil Nadu Agricultural Income-tax Act, 1955, and enabled them to pay tax accordingly.
(3.) ARGUMENTS of Mr. K. J. Chandran, learned counsel for the respective assessees, and Mr. K. Elango, learned Government Advocate, representing the Revenue, were heard.