In these appeals by Executor and Trustee of estate objection is raised against disallowance of collection charges of Rs. 11,449 and Rs. 11,150 for two years under appeal for Sewri Property, disallowance of interest of Rs. 2,798 and Rs. 2,104 in respect of same property and non-allowance of certain expenses in respect of Poona Property. other grounds of appeal are not pressed. In respect of Sewri Property, assessee claimed collection charges of Rs. 11,449 and Rs. 11,150 for assessment years under appeal. ITO had allowed expenditure, but AAC disallowed same in proceedings to AAC, rent under agreement would have automatically come to assessee and no special effort to collect same was required. In respect of same property, assessee claimed interest amounts of Rs. 6,413 and Rs. 2,878 respectively. Holding that assessee has actually paid only Rs. 3,615 and Rs. 774 AAC disallowed balance. In objecting to disallowances ld. counsel for assessee has pointed out that even though technically Trustee has not been appointed as collector of rent, actually payments to him were made for collection of rent and looking after business activities of Trust. In earlier years, overall payment made to Trustee was allocated between property income and business income, former being restricted to 6% on basis of collection charges and balance allowed for business. position continues and there was no change. According to ld. counsel, when Department has accepted liability to allow deductions for all years, there was nothing new which should prevent it to make allowance for years under appeal. Even though in case of ordinary individuals collection charges could be sought to be traced to individual payments, in case of judicial entity like Trust, persons who collect amounts due to Trust and manage its affairs, certainly substitute rent collectors in ordinary case. As regards interest, it is pointed out that amount claimed by assessee was actual interest paid and payable on borrowed capital, latter being only postponed on account of insufficiency of cash. etc. This was not case where interest on borrowed capital need not be paid by assessee being forgiven by creditor. Having heard ld. counsel for Department, we find no reason to disallow claim of assessee. That actual payment is made to Manager of Trust having properties and business is not disputed. In past allocation has been made between property and business income. extent of activity performed by Manager for business and for property m y not perhaps be very accurately computed but it cannot be denied that between two overall payment made to employee is allowable deduction. mere fact that tenants are permanent and even respectable prompt payers of rent would not make collector of rent necessary or redundant. It may be that existence of threat of collection makes payment prompt. Since there is not doubt about payments themselves, especially in case of judicial entity deduction has to be allowed. If part of it is not allowed for property, certainly it will be allowable for business. In circumstances, we direct that claim of assessee be allowed. As regards disallowance of interest, interest payable on borrowed capital is allowable deduction. mere fact that only part of payable interest was actually paid during year should not result in disallowance of balance which at any rate has only been postponed for payment. claim of interest should therefore, be allowed, in this case. assessee claimed two amount of Rs. 180 and Rs. 204, former representing collection charges and latter Municipal taxes, etc., payable to municipality. AAC disallowed same. After hearing parties, we find that question of collection charges is of same type as dealt with earlier in respect of Sewri Property. Taxes paid through society by way of society charges are also proper deduction. We, therefore, direct that in each of years sum of Rs. 384 be allowed. In result, appeal are partly allowed. *** ESTATE OF LATE K. S. KHUSHALANI v. FIRST INCOME TAX OFFICER