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“full value of consideration”

Capital GainsSection 48Section 48587 judgments

The decision most relied on for full value of consideration is CIT v. George Henderson & Co. Ltd. (66 ITR 622), cited in 82 judgments on BharatTax.

Leading authorities on full value of consideration

CIT v. George Henderson & Co. Ltd.
66 ITR 622 · 1967 · Supreme Court
82
citing judgments

The 'full value of consideration' for computing capital gains under Section 48 of the Income Tax Act, 1961 (or its predecessor, Section 12B of the 1922 Act), means the actual price bargained for and received or accrued by the parties. It does not refer to the market value or any notional value of the asset transferred.

Maria Fernandes Cheryl v. ITO (International Taxation)
123 Taxmann.com 252 · 2021 · ITAT
65
citing judgments

The amendment introducing a tolerance band (safe harbour) under section 50C, allowing a difference of up to 10% between actual sale consideration and stamp duty valuation, applies retrospectively. If the difference falls within this limit, the actual sale consideration is adopted as the full value of consideration for computing capital gains.

CIT v. Smt. Nilofer I. Singh
309 ITR 233 · 2009 · High Court
55
citing judgments

The full value of consideration for computing capital gains under Section 48 refers to the amount stated in the sale deed and cannot be substituted by the market value or a valuation by the DVO under Section 55A, unless there is evidence that the assessee actually received a consideration in excess of the stated amount.

CIT v. Gillanders Arbuthnot & Co.
87 ITR 407 · 1973 · Supreme Court
51
citing judgments

The "full value of the consideration" for computing capital gains under Section 48 of the Income Tax Act, 1961 (or Section 12B(2) of the 1922 Act), means the price actually bargained for and agreed to by the parties, not the market value of the asset transferred. In a sale transaction involving a price, the market value of the consideration is not relevant.

Dharmashibhai Sonani v. ACIT
161 ITD 627 · 2016 · ITAT
48
citing judgments

Dharmashibhai Sonani holds that if a statutory proviso is declaratory and curative, intended to remedy unintended consequences of a main provision, it should be given retrospective effect. This principle applies when determining the effective date of such provisos, including the third proviso to Section 50C(1).

CIT v. Mother India Refrigeration Industries (P.) Ltd.
155 ITR 711 · 1985 · Supreme Court
47
citing judgments

Legal fictions and deeming provisions are created for definite purposes and must be limited strictly to that purpose, not extended beyond their legitimate field or the explicit mandate of the section. This principle requires strict interpretation of such provisions.

CIT v. Shakuntala Kantilal
190 ITR 56 · 1991 · High Court
45
citing judgments

Payments made by an assessee to release property from an encumbrance or settle disputes, which are essential for a sale transaction to materialize, are allowable as a deduction under Section 48 of the Income-tax Act for computing capital gains. Such expenditure either reduces the full value of consideration or is deductible from it.

Atul G. Puranik v. ITO
132 ITD 499 · 2011 · ITAT
43
citing judgments

Section 50C of the Income Tax Act, 1961, which is a deeming provision, applies only to the transfer of "land or building or both" and therefore does not apply to the transfer of leasehold rights.

Judgments citing full value of consideration

Yogesh Gandhi, New Delhi vs. ACIT, Circle Intl Tax -1(3)(1), Delhi

In the result, the appeal filed by the assessee is allowed

ITA 2671/DEL/2025[2023-24]Status: DisposedITAT Delhi12 Nov 2025AY 2023-24

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Yogesh Gandhi, Vs. Acit, Circle, C – 2/14, Safdarjung Development Area, International Tax 1(3)(1), New Delhi – 110 021. New Delhi. (Pan : Aaipg4922F) (Appellant) (Respondent) Assessee By : Shri Rishabh Ostwal, Advocate Shri Deepak Ostwal, Ca Revenue By : Shri Vikram Singh Sharma, Sr. Dr Date Of Hearing : 21.08.2025 Date Of Order : 12.11.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Delhi - 42 [“Ld. Cit(A)”, For Short] Dated 11.03.2025 For The Assessment Year 2023-24. 2. Brief Facts Of The Case Are, Assessee Is An Nri & Also Having Income From Rent & Interest During The Year Under Consideration. The Assessee Had Sold A Property During Fy 2018-19 At Rs.2,97,50,000/- & Declared His Income In Its Return Of Income For Ay 2019-20. During The Fy 2018-

For Appellant: Shri Rishabh Ostwal, AdvocateFor Respondent: Shri Vikram Singh Sharma, Sr. DR
Section 143(1)Section 143(3)

Form 26AS for AY 2023-24. He also brought to our notice that in AY 2019-20, the assessee has declared the full value of consideration of Rs.2,97,50,000/- and offered to tax the above said income and claimed only the TDS actually deducted by the buyer during

Abdul Rahman Asad, Riyadh, Saudi Arabia vs. Deputy Commissioner of Income Tax, Intl. Tax 1(1)(1), New Delhi

In the result, the appeal filed by the assessee is allowed

ITA 2433/DEL/2025[2022-23]Status: DisposedITAT Delhi12 Nov 2025AY 2022-23

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Abdul Rahman Asad, Vs. Dcit, House No.47, Behind Jain Mandi, Circle Int. Tax 1(1)(1), Mohalla Barihat, New Delhi. Bahraich – 271 801 (Uttar Pradesh). (Pan : Aofpa6981F) (Appellant) (Respondent) Assessee By : Shri Alok Vasant, Fca Ms. Poonam Ahuja, Advocate Revenue By : Shri Vikram Singh Sharma, Sr. Dr Date Of Hearing : 21.08.2025 Date Of Order : 12.11.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Delhi - 42 [“Ld. Cit(A)”, For Short] Dated 03.03.2025 For The Assessment Year 2022-23. 2. Brief Facts Of The Case Are, The Assessee Is A Non-Resident & Filed The Original Return Of Income For Ay 2022-23 On 27.07.2022 Declaring Taxable Income Of Rs.4,86,560/- (Income From House Property Rs.4,64,444/-, Income From Other Sources Rs.32,115/- & Loss From Long

For Appellant: Shri Alok Vasant, FCAFor Respondent: Shri Vikram Singh Sharma, Sr. DR
Section 199

submissions and material placed on record. We observe that assessee has sold the property and declared long term capital gain by declaring the full value of consideration in AY 2022-23 and assessee has claimed the TDS in AY 2022-23. However, the purchaser has deposited the above tax deducted

Gourav Bhargava, Bhopal vs. Addl/JCIT(A)-1 Delhi, Delhi

Appeal is partly allowed

ITA 235/IND/2025[2023-24]Status: DisposedITAT Indore11 Nov 2025AY 2023-24

Bench: Shri B.M. Biyani

Section 139(1)Section 143(1)Section 250Section 253(5)Section 43B

paid tax: Page No. of Income offered in ITR Paper-Book | Where offered How offered Amount 38 Schedule CG - Capital Gain - | Full value of consideration 30,507 Entry No. B(4)(i) 44 Schedule OS - Income from | Interest income 2,034 other sources — Entry No. 1(b) 45 Schedule

Late Shri Khemraj Patidar (Through Wife and Legal Heir Smt. Bhagwati Patidar), Bhopal vs. Income-Tax Officer, 2(4), Bhopal

Appeal is allowed for statistical purpose

ITA 748/IND/2024[2012-13]Status: DisposedITAT Indore11 Nov 2025AY 2012-13

Bench: Shri B.M. Biyaniand**

Section 144Section 2(14)Section 48

capital asset' in terms of section 2(14)(iii) and accordingly the resultant gain is not taxable. - (ii) The AO has assessed full value of consideration of Rs. 37,01,000/- (Stamps Authority Valuation) as taxable capital gain without giving deduction of 'cost'. This approach of AO is very much

Lal Chand Meena, Jaipur vs. ITO WD 5(2), Jaipur

ITA 1074/JPR/2025[2013-14]Status: DisposedITAT Jaipur11 Nov 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Anoop Bhatia, CAFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT
Section 143(1)Section 147Section 148Section 2Section 50CSection 54F

Tribunal has taken a view that for the purposes of computation of exemption u/s 54F, the stamp duty value being the deemed full value of consideration as per section 50C is to be taken into account. The issue has been decided by the Lucknow Bench of the Tribunal ... Based on above it is submitted that, the provisions of s.50C of the Act create a limited fiction to the effect that the full value of consideration shall be substituted with the provisions u/s 48 of the Act by the amount taken

Ravi Shroff, Mumbai vs. Assistant Commissioner of Income Tax - 25(3), Mumbai, Bandra (East)

In the result, all remaining ground are allowed with the aforesaid directions

ITA 4186/MUM/2023[2015-16]Status: DisposedITAT Mumbai07 Nov 2025AY 2015-16

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 234BSection 234CSection 250Section 254(1)Section 28Section 28(1)

bank statement the assessee has received only Rs. 18.45 crore. As per computation of capital gain the assessee officer Rs. 15.64 crore as full value of consideration. As per share purchase agreement remaining block amount and indemnity escrow account will be paid after completion of 100% share transfer

Sanjeev Garg, New Delhi vs. ACIT, Circle 2(2)(2)(1), Ghaziabad

ITA 992/DEL/2024[2012-13]Status: DisposedITAT Delhi07 Nov 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Vipin Jain, FCAFor Respondent: Shri Manish Gupta, Sr. DR
Section 143(2)Section 147Section 148Section 151Section 292BSection 45Section 54

filed for AY 2012-13 as under: Asset in the case of others where proviso under section 112(1) is not exercised a Full value of consideration 2a 73,20,000 b Deductions under section 48 i Cost of acquisition after indexation bi 9,47,236 ii Cost of improvement

Babubhai Kanjibhai Sakaria, Jetpur vs. ITO WD 1(2)(1), Rajkot

In the result, the appeal filed by the assessee is allowed

ITA 156/RJT/2025[2016-17]Status: DisposedITAT Rajkot06 Nov 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 156/Rjt/2025 (Assessment Year: 2016-17) Babubhai Kanjibhai Sakariya Vs. Ito, Wd 1(2)(1), Rajkot Plot No. 82 Satyam Park, Amarnagar Aaykar Bhavan, Race Course Ring Road, Jetpur,(Rajkot-Gujarat) -360370 Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Agnps7407C (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri Rajendra Singhal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 194ASection 250Section 28

requested that his share in the interest awarded as per section 28 of the Act, might be considered as part of full value of consideration received on compulsory acquisition of agricultural land, relying upon the judgments of the Hon'ble Supreme Court in case of CIT vs. Ghanshyam ... ITAT ( supra), the assessing officer had held that the interest awarded as per section 28 of the Act, is part of full value of consideration received on compulsory acquisition of agricultural land, hence, the provisions of section 56(2) (viii) r.w.s. 145B of the Act are not applicable

Shree Salasar Sarees, Surat vs. ITO, Ward 1(2)(6), Surat

In the result, the appeal of the assessee is partly allowed for statical purpose

ITA 1154/SRT/2024[2015-16]Status: DisposedITAT Surat04 Nov 2025AY 2015-16

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1154/Srt/2024 Assessment Year: (2015-16) (Hybrid Hearing) Shree Salasar Sarees Vs. Ito, D-1401, Raghukul Textile Market, Ward – 1(2)(6), Ring Road, Surat – 395002 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abqfs5653Q (Appellant) (Respondent) Appellant By Shri Mehul Shah, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 07/08/2025 Date Of Pronouncement 04/11/2025

Section 112Section 143(3)Section 250Section 48Section 50

assets forming part of a block of assets. As per provisions of sub-section (1) of section 50 of the Act, if the full value of consideration exceeds the aggregate of the amounts mentioned in Clause (i), (ii) and (iii) u/s 50(1) of the Act, the excess shall

Shri Chhaganbhai Muljibhai Patoliya, Jetpur vs. The ITO Ward-1 (2) (3) Rajkot, Rajkot

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 477/RJT/2025[2012-13]Status: DisposedITAT Rajkot31 Oct 2025AY 2012-13

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.477/Rjt/2025 "नधा"रणवष" / Assessment Year: (2012-13) Chhaganbhai Muljibhai Patoliya, Vs The Ito Ward 1(2)(3), Radhe Park, Shreeji School, Aayakar Bhavan, Race Course, . Amarnagar Road, Rajkot (Gujarat) - 360001 Jetpur (Gujarat) - 360370 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ddrpp2365A (Appellant) (Respondent)

For Appellant: Written SubmissionFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 143(3)Section 147Section 250Section 50Section 50C

look on the provisions of the said section. For ready reference, relevant part of Section 50C is being reproduced hereunder: "Special provision for full value of consideration in certain cases. 50C. (1) Where the consideration received or accruing as a result of the transfer by an assessee of a capital

Rama Damu Bhagat, Panvel vs. ITO Ward-1, Panvel

In the result, appeal of the Assessee is allowed for statistical purpose

ITA 2109/PUN/2025[2013-14]Status: DisposedITAT Pune31 Oct 2025AY 2013-14

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2109/Pun/2025 निर्धारण वषा / Assessment Year: 2013-14 Rama Damu Bhagat, V The Income Tax Officer, Room No.4, Yashoganga S Ward-1, Panvel. Chg, Tilak Road, Panvel – 410206. Maharashtra. Pan: Bicpb8875P Appellant/ Assessee Respondent / Revenue Assessee By Ca Ajinkya Vaishampayan(Virtual Hearing) Revenue By Shri Sandeep Sathe – Jcit(Dr) Date Of Hearing 08/10/2025 Date Of Pronouncement 31/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax Appeal(Nfac) Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2013-14 Dated 25.09.2023 Emanating From The Assessment Order Under Section 144 R.W.S 147 Of The Income Tax Act, 1961 Dated 14.11.2019. The Grounds Of Appeal Raised By The Assessee Are As Under :

Section 144Section 148Section 207(2)Section 207(2)(b)Section 249(4)(b)Section 250Section 48

consideration. ITA No.2109/PUN/2025 [A] 6) The Ld. Assessing Officer erred in not allowing indexed cost of acquisition and bringing to tax the full value of consideration, thereby not following the provisions u/s 48 of the act. The Assessee craves leave to add, alter, amend or delete any of the grounds

Bimla Devi Agrawal, Kolkata vs. A.C.I.T./D.C.I.T., Circle - 34, Kolkata

In the result, the appeal filed by the assessee is dismissed

ITA 1690/KOL/2024[2017-2018]Status: DisposedITAT Kolkata31 Oct 2025AY 2017-2018

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 143(2)Section 143(3)Section 153Section 155(15)Section 250

specifically for the case of capital gain arising from the transfer of capital asset being land or building or both by taking full value of consideration to be the value adopted or assessed by the authority of a Statement Government for the purpose of stamp duty in accordance with ... gain prescribed under section 48 of the Act. {emphasis supplied} 6.1. Similarly Section 50C of the Act, is titled as 'Special provision for full value of consideration in certain cases'. Meaning thereby this section is not I.T.A. No.: 1690/KOL/2024 Assessment Year: 2017-18 Bimla Devi Agrawal. applicable to each

Inder Jaisinghani, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -5(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 974/MUM/2025[2020-21]Status: DisposedITAT Mumbai31 Oct 2025AY 2020-21

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri Rajan Vora and Shri Pranay Gandhi, CAsFor Respondent: Shri R A Dhyani, CIT DR
Section 139(1)Section 143(3)Section 244ASection 55(2)(aa)Section 55(2)(ac)

computed as under: AY 2020-21 Sr. Particulars Amount No. 1 Cost of acquisition per share (A) Rs. 500 2 Full value of consideration per share (B) Rs. 537.63 3 Capital gains per share (before claim- (C) = (A)-(B) Rs. 37.63 ing selling expenses) 4 No. of shares sold

Mukesh Kishindas Bathija, Mumbai vs. Income Tax Officer 16(3)(1), Mumbai

In the result, appeal of the assessee is allowed for statistical purposes

ITA 4935/MUM/2025[2018-19]Status: DisposedITAT Mumbai31 Oct 2025AY 2018-19

Bench: Shri Beena Pillai & Smt.Renu Jauhri

For Appellant: Shri Haridas BhatFor Respondent: Shri Annavaran Kosuri- Sr. AR
Section 250Section 50C

adopted or assessed or assessable by the stamp valuation authority on the date of agreement may be taken for the purposes of computing full value of consideration for such transfer: Provided further that the first proviso shall apply only in a case where the amount of consideration, or a part

Vishal Gift Centre - LLP, Indore vs. ACIT Central Circle - 1, Indore

Appeal is allowed for statistical purposes

ITA 347/IND/2024[2019-20]Status: DisposedITAT Indore30 Oct 2025AY 2019-20

Bench: Shri B.M. Biyani

Section 139Section 143(2)Section 143(3)Section 2(14)(iii)Section 54B

twin-claims of assessee but, however, granted a small relief in the matter of first transaction of sale by accepting that the full value of consideration, for the purpose of working long-term capital gain, shall be actual consideration of Rs. 1,00,00,000/- and not the Stamps Authority ... gain that shall be exempt from tax, the assessee submitted that fair market value on the date of diversion shall be considered as full value of consideration and such fair market value shall be considered as cost for determination of the amount of capital gain chargeable to tax subsequent

Vastu Nirman, Mumbai vs. Deputy Commissioner of Income Tax 42(1)(1), Mumbai

In the result, the appeal filed by the assessee is hereby allowed

ITA 4491/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Oct 2025AY 2018-19

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Jignesh ShahFor Respondent: Ms. Kavitha Kaushik, SR DR
Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 43C

variation is within 10%. The relevant extract of the said provision is cited herein under for ease of reference: Special provision for full value of consideration for transfer of assets other than capital assets in certain cases. 43CA. (1) Where the consideration received or accruing as a result

Ram Ji Lal Meena, Jaipur vs. ACIT, Holding Additional Charge of ITO, Ward 6(1), Jaipur

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 419/JPR/2025[2008-09]Status: DisposedITAT Jaipur28 Oct 2025AY 2008-09

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: NoneFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT-DR
Section 143(2)Section 143(3)Section 144Section 151Section 50CSection 56(2)(vii)

value of the property on date of sale. In these, circumstances, stamp duty value i.e. 50C of Rs.53,11,367/- is adopted as full value of consideration and long term capital is assessed at4 Rs.41,80,805/- as assessed by AO. This order is subject to amendment on receipt

Bhupendrabhai Bhikhabhai Patel, Anand vs. The ITO, Ward-3, Anand

In the result, the appeal of the assessee is allowed for statistical purposes, in the interests of justice

ITA 1005/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2012-13

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri S. N. Divatia & Shri Samir Vora, ARsFor Respondent: Shri Suresh Chand Meena, Sr. DR
Section 142(1)Section 147Section 148Section 50C

explanation and held that under Section 50C of the Act, the value adopted for stamp duty purposes must be taken as the full value of consideration for computing capital gains. The Assessing Officer also noted inconsistencies in the assessee's disclosure while the assessee had earlier shown income of Rs.1 ... consideration is whether the Assessing Officer was justified in adopting the value determined by the Sub-Registrar for stamp duty purposes as the full value of consideration under Section 50C(1) of the Act, without referring the matter to the Departmental Valuation Officer (DVO) under Section

ACIT, Non-Corporate Circle 7(1), Chennai vs. Late Shri Mahaveer Bhandari, Legal Heir- Smt. Lalitha Bhandari, Chennai

ITA 2785/CHNY/2024[2016]Status: DisposedITAT Chennai15 Oct 2025

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2785/Chny/2024 िनधा"रण वष"/Assessment Year : 2016-17 The Asst. Commissioner Of Late Shri Mahaveer Bhandari, Income Tax, Rep. By Legal Heir Smt. Lalitha Non-Corporate Circle 7(1), Vs. Bhandari, Chennai. 9, Athipattan Street, Mount Road, Chennai – 600 002. Pan: Aadpb 877A (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. Anitha, Addl.Cit ""यथ" क" ओर से/Respondent By : Shri Ajith Kumar Chordia, Ca (Through Virtual Mode) सुनवाई क" तारीख/Date Of Hearing : 18.07.2025 घोषणा क" तारीख/Date Of Pronouncement : 15.10.2025

For Appellant: Ms. Anitha, Addl.CITFor Respondent: Shri Ajith Kumar Chordia, CA
Section 143(1)Section 143(3)Section 28Section 56(2)(vii)

adjustment in the annual report of 16-17. Since there is no actual flow of cash, and being an exchange of share, the Full Value of consideration has to be the Fair market value of the shares as on date of transfer. Hence the Full value of consideration is adopted ... Rs.586 per share and LTCG is therefore determined by adopting the full value of consideration at Rs.586 per share, which results in the addition of Rs.8,84,50,194/-. The AO iterated that the benefit derived in the form of capital gains from the sale of shares of the Company

Incometax Officer, Ward-3(1), Visakhapatnam vs. Surendra Nath Gubbala, Visakhapatnam

ITA 482/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam10 Oct 2025AY 2020-21

Bench: Us:

Section 143(3)Section 144BSection 48

that as per Section 48 of the Act the income chargeable under the head “Capital gains” shall be computed by deducting from the full value of consideration received or accruing as a result of the transfer of the capital asset the amounts therein specified, viz. (i). expenditure incurred wholly