CIT v. Malayalam Plantations Ltd.

53 ITR 140Supreme Court of India1964#460 most cited

What is CIT v. Malayalam Plantations Ltd. authority for?

The expression "for the purpose of business" is wider in scope than "for the purpose of earning profits" and encompasses expenditures made for commercial expediency, business preservation, administration, and modernization.

201

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2006 to 2025.

Also referred to as

CIT v. Malayalam Plantations Ltd. · 53 ITR 140 · Section 37 · Section 36(1)(iii) · Income Tax Act 1961 · for the purpose of business · commercial expediency · scope of business purpose · deductibility of expenditure · earning profits

Sections most often in play

Section 36(1)(iii)Section 1961Section 143(3)Section 37Section 1872: Section 62Section 194(I)(b)Section 1963: Rule 29Section 24

Issues it is cited on

recognised provident fundsection 50bsection 43b(f)approved gratuity fundsection 40a(9)section 211wholly and exclusively for businesssection 35dslump salesection 32(1)(ii)domestic companyfull value of consideration

Judgments citing CIT v. Malayalam Plantations Ltd.

M/S. Sunil & Company, Jodhpur vs. ACIT, Circle-1, Jodhpur

In the result, appeal of the assessee is allowed

ITA 502/JODH/2018[2004-05]Status: DisposedITAT Jodhpur03 Aug 2023AY 2004-05

Bench: Its Hearing Before Your Honour.”

Section 143(2)Section 143(3)Section 36(1)(iii)

…and income would not present true and fair picture. k. The expression for the purpose of business was explained by the Hon'ble Apex Court in the matter of Madhav Prasad Jatia vs. CIT (SC), 118 ITR 200 (SC) by referring to the decision of Malyalam Plantation, 53 ITR 140 (SC), wherein it was held as It cannot be disputed that the expression "for the purpose of business" occurring in s 10(2) (ii) as also in 10(2) (xv) is wider in scope than the expression "for the purpose of earning income profits or gains" occurring in s 12[2] of the Act and, therefore, the scope for allowing a deduction under s 10/21 (1) or 10(2)…

ACIT, Circle- 17(1), New Delhi vs. Modi Rubber Ltd., New Delhi

In the result the appeal of the Revenue is dismissed

ITA 4864/DEL/2018[2011-12]Status: DisposedITAT Delhi26 Jul 2023AY 2011-12

Bench: Shri G.S. Pannu, Hon’Ble & Shri Amit Shuklaasstt. Year: 2011-12

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Dr. Maninder Kaur, Sr. Dr
Section 143(3)Section 14ASection 37(1)

…Making of estimation for disallowance under such circumstances and facts of the case is not permissible. Accordingly, we do not find any infirmity in the order of the Id. CIT(A) who has relied upon the following decisions: a)CIT Vs. Malayalam Plantations Ltd 53 ITR 140 (SC) b) CIT V Birla Cotton Spinning & Weaving Mills Ltd 82 ITR 166 [SC] c) Madhav Prasad Jatia Vs. CIT 118 ITR 200 [SC] 8. Reliance was also placed by the Id. counsel for the assessee on the decision of the Hon'ble Supreme Court in the case of J.J. Enterprises Vs. CIT reported at 254 ITR 216 [SC] where, as per the ‘Head Notes’, it has been held a…

Addl. CIT, Special Range- 4, New Delhi vs. Hindustan Coca-Cola Beverages Pvt. Ltd., New Delhi

In the result, appeal is partly allowed for statistical

ITA 1125/DEL/2018[2005-06]Status: DisposedITAT Delhi07 Jun 2023AY 2005-06

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 143(3)Section 271(1)(c)

…ith the third parties, the expenditures are allowable. In support of such contention, he relied upon the following decisions: i. Campa Beverages (P.) Ltd. Vs. Inspecting Assistant Commissioner [1990] 34 ITD 241 (Delhi) ii. CIT Vs. Malayalam Plantations Ltd. 53 ITR 140 (SC) iii. CIT Vs. Birla Cotton Spinning & Weaving Mills Ltd., 82 ITR 166 (SC) iv. Madhav Prasad Jatia Vs. CIT, 118 ITR 200 (SC) v. S.A. Builders Ltd. Vs. CIT, 288 ITR 1 (SC) 21. The learned Departmental Representative submitted, the assessee has not furnished any evidence at all to establish on record that the liability has actually accrued and n…

Addl. CIT, Special Range- 4, New Delhi vs. Hindustan Coca-Cola Beverages Pvt. Ltd., New Delhi

In the result, appeal is partly allowed for statistical

ITA 1124/DEL/2018[2004-05]Status: DisposedITAT Delhi07 Jun 2023AY 2004-05

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 143(3)Section 271(1)(c)

…ith the third parties, the expenditures are allowable. In support of such contention, he relied upon the following decisions: i. Campa Beverages (P.) Ltd. Vs. Inspecting Assistant Commissioner [1990] 34 ITD 241 (Delhi) ii. CIT Vs. Malayalam Plantations Ltd. 53 ITR 140 (SC) iii. CIT Vs. Birla Cotton Spinning & Weaving Mills Ltd., 82 ITR 166 (SC) iv. Madhav Prasad Jatia Vs. CIT, 118 ITR 200 (SC) v. S.A. Builders Ltd. Vs. CIT, 288 ITR 1 (SC) 21. The learned Departmental Representative submitted, the assessee has not furnished any evidence at all to establish on record that the liability has actually accrued and n…

DCIT, New Delhi vs. M/S Hindustan Coca Cola Beverages Pvt. Ltd., New Delhi

In the result, appeal is partly allowed for statistical

ITA 4589/DEL/2015[2009-10]Status: DisposedITAT Delhi07 Jun 2023AY 2009-10

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 143(3)Section 271(1)(c)

…ith the third parties, the expenditures are allowable. In support of such contention, he relied upon the following decisions: i. Campa Beverages (P.) Ltd. Vs. Inspecting Assistant Commissioner [1990] 34 ITD 241 (Delhi) ii. CIT Vs. Malayalam Plantations Ltd. 53 ITR 140 (SC) iii. CIT Vs. Birla Cotton Spinning & Weaving Mills Ltd., 82 ITR 166 (SC) iv. Madhav Prasad Jatia Vs. CIT, 118 ITR 200 (SC) v. S.A. Builders Ltd. Vs. CIT, 288 ITR 1 (SC) 21. The learned Departmental Representative submitted, the assessee has not furnished any evidence at all to establish on record that the liability has actually accrued and n…

DCIT, New Delhi vs. M/S Hindustan Coca Cola Beverages Pvt. Ltd., New Delhi

In the result, appeal is partly allowed for statistical

ITA 4588/DEL/2015[2008-09]Status: DisposedITAT Delhi07 Jun 2023AY 2008-09

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 143(3)Section 271(1)(c)

…ith the third parties, the expenditures are allowable. In support of such contention, he relied upon the following decisions: i. Campa Beverages (P.) Ltd. Vs. Inspecting Assistant Commissioner [1990] 34 ITD 241 (Delhi) ii. CIT Vs. Malayalam Plantations Ltd. 53 ITR 140 (SC) iii. CIT Vs. Birla Cotton Spinning & Weaving Mills Ltd., 82 ITR 166 (SC) iv. Madhav Prasad Jatia Vs. CIT, 118 ITR 200 (SC) v. S.A. Builders Ltd. Vs. CIT, 288 ITR 1 (SC) 21. The learned Departmental Representative submitted, the assessee has not furnished any evidence at all to establish on record that the liability has actually accrued and n…

Hindustan Coca-Cola Beverages Pvt. Ltd., Gurgaon vs. Deputy Commissioner of Income-Tax, New Delhi

In the result, appeal is partly allowed for statistical

ITA 3449/DEL/2015[2009-10]Status: DisposedITAT Delhi07 Jun 2023AY 2009-10

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 143(3)Section 271(1)(c)

…ith the third parties, the expenditures are allowable. In support of such contention, he relied upon the following decisions: i. Campa Beverages (P.) Ltd. Vs. Inspecting Assistant Commissioner [1990] 34 ITD 241 (Delhi) ii. CIT Vs. Malayalam Plantations Ltd. 53 ITR 140 (SC) iii. CIT Vs. Birla Cotton Spinning & Weaving Mills Ltd., 82 ITR 166 (SC) iv. Madhav Prasad Jatia Vs. CIT, 118 ITR 200 (SC) v. S.A. Builders Ltd. Vs. CIT, 288 ITR 1 (SC) 21. The learned Departmental Representative submitted, the assessee has not furnished any evidence at all to establish on record that the liability has actually accrued and n…

Hindustan Coca-Cola Beverages Pvt. Ltd., Gurgaon vs. Deputy Commissioner of Income-Tax, New Delhi

In the result, appeal is partly allowed for statistical

ITA 3448/DEL/2015[2008-09]Status: DisposedITAT Delhi07 Jun 2023AY 2008-09

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 143(3)Section 271(1)(c)

…ith the third parties, the expenditures are allowable. In support of such contention, he relied upon the following decisions: i. Campa Beverages (P.) Ltd. Vs. Inspecting Assistant Commissioner [1990] 34 ITD 241 (Delhi) ii. CIT Vs. Malayalam Plantations Ltd. 53 ITR 140 (SC) iii. CIT Vs. Birla Cotton Spinning & Weaving Mills Ltd., 82 ITR 166 (SC) iv. Madhav Prasad Jatia Vs. CIT, 118 ITR 200 (SC) v. S.A. Builders Ltd. Vs. CIT, 288 ITR 1 (SC) 21. The learned Departmental Representative submitted, the assessee has not furnished any evidence at all to establish on record that the liability has actually accrued and n…

Addl. CIT, Special Range- 1, New Delhi vs. Amway India Enterprises Pvt. Ltd., New Delhi

In the result, the appeal of the revenue is dismissed

ITA 6707/DEL/2018[2012-13]Status: DisposedITAT Delhi08 May 2023AY 2012-13

Bench: Shri C.M. Garg & Dr. B. R. R. Kumaraddl. Cit, Vs. Amway India Enterprises Pvt. Ltd, 1St Floor, Plot No. 8, Elegance Special Range-1, New Delhi Tower, Jasola, New Delhi -110025 (Appellant) (Respondent) Pan: Aaaca5603Q Assessee By : Sh. Sudesh Garg, Adv Sh. Prince Bansal, Ca Ms. Bhavya Garg, Ca Revenue By: Sh. P. Praveen Sidharth, Cit Dr Date Of Hearing 16/02/2023 Date Of Pronouncement 08/05/2023

For Appellant: Sh. Sudesh Garg, AdvFor Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 32Section 37(1)

…y be admissible as a deduction under section 10(2)(xv), it is not necessary that the primary motive in incurring it must be directly to earn income thereby (Sree Meenakshi Mills Ltd. Vs. CIT (1967) 63 ITR 207 (SC). In CIT Vs. Malayalam Plantations Ltd. (1960) 53 ITR 140, the Supreme Court has observed at page 150, that: "The expression for the purpose of the businesses is wider in scope than the expression 'for the purpose of earning profits. Its range is wide, it may take in not only the day to day running of a business but also the rationalisation of its administration and modernisation of its machinery, it may…

M/S. Rmz Hotels Private Limited, Bangalore vs. National E-Assessment Centre, Delhi

In the result, the appeal of the assessee is allowed

ITA 954/BANG/2022[2018-19]Status: DisposedITAT Bangalore22 Feb 2023AY 2018-19

Bench: Shri Chandra Poojariassessment Year: 2018-19

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for Department
Section 234Section 255Section 255(3)Section 36

…s Private Limited, Bangalore Page 30 of 79 It has been repeatedly held by this Court that the expression "for the purpose of business" is wider in scope than the expression " for the purpose of earning profits" vide CIT vs. Malayalam Plantations Ltd. (1964) 53 ITR 140, CIT vs. Birla Cotton Spinning & Weaving Mills Ltd (1971) 82 ITR 166 etc. The High Court and the other authorities should have examined the purpose for which the assessee advanced the money to its sister concern, and what the sister concern did with this money, in order to decide whether it was for commercial expediency, but that has not been done…

Mseb Holding Company Ltd., Mumbai vs. ACIT (Hq) (Judl) to the CIT 14, Mumbai

In the result, the appeal of the assessee

ITA 3374/MUM/2019[2012-13]Status: DisposedITAT Mumbai30 Nov 2022AY 2012-13

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2012-13

For Appellant: Mr. Ketan Ved, ARFor Respondent: Mr. T. Shankar, CIT-DR
Section 253(3)Section 263

…ITR 377) vi. CIT v. Navsari Cotton and Silk Mills L CIT v. Navsari Cotton and Silk Mills Ltd. (135 |TR 546) td. (135 |TR 546) vii. Ravi Marketing (P) Ltd. v. CIT 280 ITR 519) Ravi Marketing (P) Ltd. v. CIT 280 ITR 519) viii. CIT v. Malayalam Plantations Ltd. (53 ITR 140) CIT v. Malayalam Plantations Ltd. (53 ITR 140) CIT v. Malayalam Plantations Ltd. (53 ITR 140) 9. Assessee further submitted that in view of the foregoing and Assessee further submitted that in view of the foregoing and Assessee further submitted that in view of the foregoing and considering the facts and circumstances of the assessee's case and c…

Mseb Holding Company Limited, Mumbai vs. Principal Commissioner of Income Tax 1, Mumbai

In the result, the appeal of the assessee

ITA 1181/MUM/2018[2012-13]Status: DisposedITAT Mumbai30 Nov 2022AY 2012-13

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2012-13

For Appellant: Mr. Ketan Ved, ARFor Respondent: Mr. T. Shankar, CIT-DR
Section 253(3)Section 263

…ITR 377) vi. CIT v. Navsari Cotton and Silk Mills L CIT v. Navsari Cotton and Silk Mills Ltd. (135 |TR 546) td. (135 |TR 546) vii. Ravi Marketing (P) Ltd. v. CIT 280 ITR 519) Ravi Marketing (P) Ltd. v. CIT 280 ITR 519) viii. CIT v. Malayalam Plantations Ltd. (53 ITR 140) CIT v. Malayalam Plantations Ltd. (53 ITR 140) CIT v. Malayalam Plantations Ltd. (53 ITR 140) 9. Assessee further submitted that in view of the foregoing and Assessee further submitted that in view of the foregoing and Assessee further submitted that in view of the foregoing and considering the facts and circumstances of the assessee's case and c…

Petronet Mhb Limited, Bangalore vs. The Income Tax Officer, Ward-5(1)(3), Bangalore

In the result, both the appeal of the assessee is allowed

ITA 789/BANG/2022[2013-14]Status: DisposedITAT Bangalore28 Nov 2022AY 2013-14

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2013-14

For Appellant: Shri M.G Vinay Simha, C.AFor Respondent: Shri K.R Narayana, Addl. CIT (DR)
Section 143(3)Section 154Section 37(1)

…7 talks about the expenditure wholly and exclusively for the purposes of the business whereas, Section 57(iii) talks about the expenditure wholly and exclusively for the purpose of making or earning such income. 8.5 In CIT v. Malayalam Plantations Ltd. [1964] 53 ITR 140 (SC), the Supreme Court observed that "the expression 'for the purpose for the business' is wider in scope than the expression 'for the purpose of earning profits'". Similar observation has also been made in CIT v. Birla Cotton Spg. & Wvg. Mills Ltd. [1971] 82 ITR 166 (SC), where the Supreme Court expressed the view that the expression 'for the pu…

ITO Ward - 2(2), New Delhi vs. All Check Deals India Pvt. Ltd., New Delhi

The appeal of the revenue is dismissed

ITA 2923/DEL/2019[2014-15]Status: DisposedITAT Delhi24 Nov 2022AY 2014-15

Bench: Shri Shamim Yahya & Shri Anubhav Sharmaito, Vs. All Check Deals India Pvt. Ltd, Ward-2(2). 94, Meghdoot Building, Gf- New Delhi 12A, Nehru Place, New Delhi (Appellant) (Respondent)

For Appellant: Shri Sharat Rao, AdvFor Respondent: Shri Kanav Bali, Sr. DR
Section 143(3)Section 37(1)Section 40Section 40A(2)(a)Section 94C

…same were wholly and exclusively for the business of the appellant and same are allowable. Hence, the disallowance made by the AO is deleted. The appellant has relied upon the judgments of Hon’ble Supreme Court in the case of CIT Vs. Malyalam Plantation Ltd. 53 ITR 140, Shri Meenakshi Mills Ltd. Vs. CIT, 63 ITR 207, CIT Vs. Dhanrajgirji Raja Narsingirji, 94 ITR 544 (SC), Birla Cotton Spinning and Weaving Mills Ltd. Vs. CIT, 64 ITR 568 (Calcutta), CIT Vs. Modi Revlon Pvt. Ltd., 26 taxmann.com 133 (Delhi) in support of its contention that expenses incurred for the purposes of business has to be allowed. These judg…

M/S Avantika Infraventure (P) Ltd., Allahabad vs. DCIT, Central Circle, Varanasi

In the result, the appeals of the assessee for the Assessment Years

ITA 23/VNS/2020[2013-2014]Status: DisposedITAT Varanasi13 Oct 2022AY 2013-2014

Bench: Shri.Vijay Pal Rao & Shri Ramit Kochar

For Appellant: NoneFor Respondent: Sh. R.K. Vishwakarma, CIT DR
Section 153ASection 234ASection 36

…ern was by way of commercial expediency. 29. It has been repeatedly held by this Court that the expression "for the purpose of business" is wider in scope than the expression " for the purpose of earning profits" vide CIT vs. Malayalam Plantations Ltd. (1964) 53 ITR 140, CIT vs. Birla Cotton Spinning & Weaving Mills Ltd (1971) 82 ITR 166 etc. 30. The High Court and the other authorities should have examined the purpose for which the assessee advanced the money to its sister concern, and what the sister concern did with this money, in order to decide whether it was for commercial expediency, but that has not been…

M/S Avantika Infraventure (P) Ltd., Allahabad vs. DCIT, Central Circle, Varanasi

In the result, the appeals of the assessee for the Assessment Years

ITA 22/VNS/2020[2012-2013]Status: DisposedITAT Varanasi13 Oct 2022AY 2012-2013

Bench: Shri.Vijay Pal Rao & Shri Ramit Kochar

For Appellant: NoneFor Respondent: Sh. R.K. Vishwakarma, CIT DR
Section 153ASection 234ASection 36

…ern was by way of commercial expediency. 29. It has been repeatedly held by this Court that the expression "for the purpose of business" is wider in scope than the expression " for the purpose of earning profits" vide CIT vs. Malayalam Plantations Ltd. (1964) 53 ITR 140, CIT vs. Birla Cotton Spinning & Weaving Mills Ltd (1971) 82 ITR 166 etc. 30. The High Court and the other authorities should have examined the purpose for which the assessee advanced the money to its sister concern, and what the sister concern did with this money, in order to decide whether it was for commercial expediency, but that has not been…

Deputy Commissioner of Income-Tax Circle -5, Pune vs. Serum Institute of India Pvt Ltd., Pune

In the result, the appeal filed by the Revenue stands dismissed

ITA 323/PUN/2021[2013-14]Status: DisposedITAT Pune15 Sept 2022AY 2013-14
For Appellant: Shri Percy PardiwallaFor Respondent: Shri J. P. Chadraker
Section 10ASection 14ASection 35Section 35(1)

…nery, as such, is purchased. In such an event, either it may be disallowed altogether or it may be allowed treating it as a revenue expenditure. In aforesaid circumstances, applying the decision of the Supreme Court in CIT v. Malayalam Plantations Ltd. [1964] 53 ITR 140 it was to be 23 held that the Tribunal was not justified in holding the expenditure in question was capital expenditure and in disallowing the claim of the assessee for deduction under section 37(1).” We also find that the AO for assessment years 2011-12 and 2012-13 pursuant to the remand made by the ITAT accepted vide order dated 26.12.2019 passe…

M/S Bosch Limited, Bangalore vs. Assistant Commissioner of Income Tax Ltu Circle-1, Bangalore

In the result, appeal of the assessee is partly allowed

ITA 1629/BANG/2018[2013-14]Status: DisposedITAT Bangalore13 Sept 2022AY 2013-14

Bench: Shri N.V. Vasudevan & Ms. Padmavathy Sassessment Year : 2013-14 Bosch Limited, Vs. The Assistant Commissioner Hosur Road, Adugodi, Of Income Tax, Ltu, Bangalore – 560 030. Circle 1, Pan: Aaacm 9840P Bangalore. Appellant Respondent Appellant By : Shri Percy Pardiwala, Advocate Respondent By : Shri V S Chakrapani, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 01.09.2022 Date Of Pronouncement : 13.09.2022 O R D E R Per Padmavathy S.2. This Appeal Is Against The Order Of The Cit(Appeals), Bangalore-9, Bangalore Dated 31.3.2018 For The Assessment Year 2013- 14. 3. The Assessee Raised Grounds Pertaining To The Following Issues:- Deduction U/S. 35(2Ab) Computed On Net Expenditure As Opposed To Gross Expenditure Disallowance Of Provision For Bad & Doubtful Debts I) Disallowance Of Provision For Long Term Service Award Disallowance Of Expenditure U/S. 14A Of The Act Ii) Page 2 Of 67

For Appellant: Shri Percy Pardiwala, AdvocateFor Respondent: Shri V S Chakrapani, CIT(DR)(ITAT), Bengaluru
Section 14ASection 35Section 37Section 43BSection 80J

…7 talks about the expenditure wholly and exclusively for the purposes of the business whereas, Section 57(iii) talks about the expenditure wholly and exclusively for the purpose of making or earning such income. 8.5 In CIT v. Malayalam Plantations Ltd. [1964] 53 ITR 140 (SC), the Supreme Court observed that "the expression 'for the purpose for the business' is wider in scope than the expression 'for the purpose of earning profits'". Similar observation has also been made in CIT v. Birla Cotton Spg. & Wvg. Mills Ltd. [1971] 82 ITR 166 (SC), where the Supreme Court expressed the view that the expression 'for the pu…

M/S. V.V.V. & Sons Edible Oils Ltd., Virudhunagar vs. DCIT, Central-1, Madurai

In the result, the appeals of the assessee in ITA Nos

ITA 2281/CHNY/2019[2016-17]Status: DisposedITAT Chennai05 Aug 2022AY 2016-17

Bench: Shri Mahavir Singhand Shri G. Manjunatha

For Appellant: Shri P. G. Sekar, C.A ""For Respondent: Dr. S. Palani Kumar,CIT
Section 143(3)

…ssessee in ITA No.2277/CHNY/2019 for assessment year 2012-13 is as regards to disallowance of foreign tour expenses of Rs.13,89,450/-. For this, assessee has raised the following ground:- FOREIGN TOUR The Supreme Court in CIT vs MALAYALAM PLANTATIONS LTD 1964 53 ITR 140 has observed The expression for the purpose of the expression for the purpose of earning profits The purpose shall be for the purpose of the business that is to say the expenditure incurred shall be jor the carrying on of the business and the assessee shall incur it in his capacity as a person carrying on the business Working through the year one…

M/S. V.V.V. & Sons Edible Oils Ltd., Virudhunagar vs. DCIT, Central-1, Madurai

In the result, the appeals of the assessee in ITA Nos

ITA 2280/CHNY/2019[2015-16]Status: DisposedITAT Chennai05 Aug 2022AY 2015-16

Bench: Shri Mahavir Singhand Shri G. Manjunatha

For Appellant: Shri P. G. Sekar, C.A ""For Respondent: Dr. S. Palani Kumar,CIT
Section 143(3)

…ssessee in ITA No.2277/CHNY/2019 for assessment year 2012-13 is as regards to disallowance of foreign tour expenses of Rs.13,89,450/-. For this, assessee has raised the following ground:- FOREIGN TOUR The Supreme Court in CIT vs MALAYALAM PLANTATIONS LTD 1964 53 ITR 140 has observed The expression for the purpose of the expression for the purpose of earning profits The purpose shall be for the purpose of the business that is to say the expenditure incurred shall be jor the carrying on of the business and the assessee shall incur it in his capacity as a person carrying on the business Working through the year one…