“wholly and exclusively for business”

Business ExpensesSection 37Section 37265 judgments

The decision most relied on for wholly and exclusively for business is Hero Cycles Pvt. Ltd. v. CIT (379 ITR 347), cited in 361 judgments on BharatTax.

Leading authorities on wholly and exclusively for business

Hero Cycles Pvt. Ltd. v. CIT

379 ITR 347 · 2015 · Supreme Court

361

citing judgments

The Revenue cannot substitute its judgment for that of a businessman regarding the necessity or reasonableness of an expenditure. If an expense is incurred wholly and exclusively for business purposes, it is deductible, and the Revenue cannot question its commercial expediency.

Indian Molasses Co. Pvt. Ltd. v. CIT

37 ITR 66 · 1959 · Supreme Court

206

citing judgments

Expenditure is defined as money paid out or away, which is gone irretrievably. To be deductible under Section 37(1), expenditure must be wholly and exclusively for business, not capital or personal, and not fall under specific provisions of Sections 30 to 36, often justifiable on grounds of commercial expediency.

CIT v. Dhanrajgirji Raja Narasingirji

91 ITR 544 · 1973 · Supreme Court

154

citing judgments

The revenue cannot question the commercial expediency or wisdom of an expenditure incurred by a businessman, as the businessman is the best judge of their own business interests. The department's role is limited to verifying if the expenditure was genuinely incurred and was wholly and exclusively for business purposes.

Sree Meenakshi Mills Ltd. v. Commissioner of Income Tax

31 ITR 28 · 1957 · Supreme Court

137

citing judgments

Expenditure incurred for commercial expediency, even without a direct or immediate benefit but indirectly facilitating business, is deductible as laid out wholly and exclusively for trade. The scope of reference jurisdiction under Section 66 is limited to questions of law, allowing challenges to Tribunal findings of fact only if they are perverse, unreasonable, or lack evidence.

Prakash Cotton Mills Pvt. Ltd. v. CIT

201 ITR 684 · 1993 · Supreme Court

133

citing judgments

Compensatory interest or damages paid for a breach of contract, arising in the normal course of business, are allowable as a deduction under section 37(1) as wholly and exclusively incurred for business purposes. This principle extends to indirect taxes paid in the course of business, which are admissible as business expenditure.

CIT v. Nestle India Ltd.

14 Taxmann 99 · 1983 · High Court

125

citing judgments

Club entrance fees, if incurred wholly and exclusively for business purposes, are allowable as revenue expenditure under Section 37(1). Furthermore, an order holding a deductor liable for TDS defaults under Section 201 must be preceded by an inquiry into the deductee's actual tax payment.

Lachminarayan Madan Lal v. CIT

86 ITR 439 · 1972 · Supreme Court

citing judgments

Even with an existing agreement, the deductibility of an amount claimed as an expenditure, such as commission, must be decided based on the specific facts and circumstances of each case, to ascertain if it was laid out wholly and exclusively for business purposes.

Haji Aziz & Abdul Shakoor Bros. v. CIT

41 ITR 350 · 1961 · Supreme Court

citing judgments

Penalties paid for a breach of law or contravention of statutory provisions are not allowable deductions as business expenditure because they cannot be considered wholly and exclusively laid out for the purpose of the business. This principle is now enshrined in Explanation 1 to Section 37(1) of the Income-tax Act, 1961.

Judgments citing wholly and exclusively for business

Piramal Enterprises Limited, Mumbai vs. The Assistant Commissioner of Income Taxcircle 7(3)(1), Mumbai

In the result, the appeal of the assessee bearing ITA 3436/Mum/2024 is allowed

ITA 3436/MUM/2024[2011-12]Status: DisposedITAT Mumbai19 Nov 2024AY 2011-12

Bench: Shri. Anikesh Banerjee & Smt. Renu Jauhri

For Appellant: Shri Ronak Doshi & Priyank GalaFor Respondent: Shri. Krishna Kumar, CIT

Section 143(3)Section 147Section 148Section 250Section 28Section 37Section 37(1)Section 41(1)

books of account was by way of raising bogus vouchers. Expenditure which was bogus could not be the expenditure which was wholly and exclusively for business purpose and it could 5 Piramal Enterprises Limited not be allowed u/s.37(1) of the Act. Therefore, the action of the AO to disallow

Ravindra Madanlal Khandelwal, Akola vs. DCIT/ACIT Circle, Akola

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

ITA 375/NAG/2024[2018-19]Status: DisposedITAT Nagpur18 Nov 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Sandipkumar Salunke

Section 142(1)Section 143Section 144BSection 68

upheld, as the assessee did not meet the burden of proof required to establish that these expenses were incurred wholly and exclusively for business purposes. Thus the ground raised by the assessee was dismissed and addition of ` 97,66,308, made by the Assessing Officer was upheld. 5 Ravindra Madanlal

M/S. Bill Forge Private Limited, Bangalore vs. The Assistant Commissioner of Income Tax (Ltu), Circle - 1, Bangalore

In the result appeal is allowed partly to extent indicated above

ITA 1161/BANG/2019[2012-13]Status: DisposedITAT Bangalore18 Nov 2024AY 2012-13

Bench: Shri Maharishi Prashant & Shri Prakash Chand Yadavshri Chandra Poojariassessment Year : 2012-13 Mahindra Cie Automotive Ltd., Vs. Acit (Ltu), Formerly Known As Bill Forge Pvt. Ltd., Circle –1, #9C, Hosur Road, Bangalore. Bommasandra Industrial Area, Bangalore – 560 099. Pan : Aaacb 8620 J Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Mrs. Neera Malhotra Cit Dr Date Of Hearing : 07.11.2024 Date Of Pronouncement : 18.11.2024

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Mrs. Neera Malhotra CIT DR

Section 143(2)Section 143(3)Section 32

Appellant. 6. The LAA erred in not appreciating the fact that travelling expenditure of Rs. 6,54,487/- is incurred wholly and exclusively for business purpose and undertook additions merely on the basis of surmises by considering an element of personal nature. 3. The brief fact of the case shows

Amazon Web Services India Private Limited, Delhi vs. Principal Commissioner of Income Tax, Delhi-1, Delhi

In the result, appeal of the assessee is allowed in the aforesaid manner

ITA 2706/DEL/2024[2018-19]Status: DisposedITAT Delhi28 Oct 2024AY 2018-19

Bench: Shri Shamim Yahya & Shri Sudhir Kumara.Yr. : 2018-19 Amazon Web Services India Vs. Principal Commissioner Of Private Limited, Income Tax, Delhi-1, Block-3, 14Th Floor, Unit Delhi Nos. 1401 To 1421, C.R. Building, I.P. Estate, New International Trade Delhi Tower, Nehru Place, New Delhi – 110 019 (Pan: Aajca9880A) (Appellant) (Respondent)

For Appellant: Shri Ajay Vohra, Sr. Adv., Ms. DeepashreeFor Respondent: Mr. Javed Akhtar, CIT(DR)

Section 143(3)Section 263Section 92C

document for Novation is held as sham & bogus. The nature of this expenditure is such that it is held to be not wholly and exclusively for business and therefore held to be not allowable expenditure u/s 37. In view of overall facts of the case and non-inquiry

Infiben Avenues Ltd (Formerly Infibeam Incorporation Ltd., Ahmedabad vs. The Pr. CIT-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 108/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Aseem L. Thakkar, A.RFor Respondent: Shri A.P. Singh, CIT DR

Section 143(3)Section 263Section 37

should not be covered under Sections 30 to 36, it must not constitute capital or personal expenses, and it must be incurred wholly and exclusively for business purposes. In light of these criteria, PCIT was of the view that it is evident that the expenses claimed by the Assessee Company

M/S. Bandhan Bank Ltd. (Erstwhile Ghosh Finance Ltd), Kolkata vs. DCIT, Cir-5(1), Kol, Kolkata

In the result, the appeal of the assessee is allowed

ITA 465/KOL/2023[2016-17]Status: DisposedITAT Kolkata26 Aug 2024AY 2016-17

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2016-17

For Appellant: Shri Biswanath Paul, FCAFor Respondent: Shri Subhro Das, Addl. CIT, Sr. DR

Section 143(3)Section 17(2)(vi)Section 192Section 250Section 37

ESOS discount cannot not be treated as personal expenditure of the company Wholly and exclusively for the purpose of business: The term 'wholly and exclusively for business has not been defined under the Act. However, judicial authorities have time and again interpreted this phrase. The adverb 'wholly' in the phrase

Avirat Rajendra Sonpal, Mumbai vs. DCIT, CPC, Bangalure

ITA 2198/MUM/2024[2018-19]Status: DisposedITAT Mumbai22 Jul 2024AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Anikesh Banerjee, Jm Avirat Rajendra Sonpal Dy. Commissioner Of 54/B, Miramar Co-Op Hsg, Income Tax, Cpc, Society, 3, L. Jagmohandas Bangaluru, Vs. Marg Napeansea Road, Piramal Chambers, Lalbaug, Mumbai-400 036 Mumbai-400 012 (Appellant) (Respondent) Pan No. Aahps2278R Assessee By : Shri Vishal D. Shah, Ar Revenue By : Shri Manoj Kumar Sinha, Dr Date Of Hearing: 11.07.2024 22.07.2024 Date Of Pronouncement :

For Appellant: Shri Vishal D. Shah, ARFor Respondent: Shri Manoj Kumar Sinha, DR

Section 139(1)Section 143(1)Section 250Section 37(1)Section 44A

Color Ltd. (2009) 180 taxmann.com 82 (2010 326 ITR 425 held that admission fees paid to the club towards corporate membership is wholly and exclusively for business purpose and is revenue in nature. Paragraphs 5 to 5.3 of Samtel Color Ltd. (supra) read as under 5. Having heard the learned

Sitas Films & Tv Productions P.Ltd, New Delhi vs. DCIT, Circle-23(2), New Delhi

Appeal of the assessee is dismissed

ITA 2137/DEL/2018[2013-14]Status: DisposedITAT Delhi28 Jun 2024AY 2013-14

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singhassessment Year: 2013-14

Section 143(3)Section 271(1)(c)Section 37

erred both on facts and in law in upholding the addition of Rs. 13,01,260/- on account of revenue expenditure incurred wholly and exclusive for business purpose. 3. That the CIT (A) has erred in confirming the addition of Rs. 3,07,500/- for the rent expenses. The Rent ... purely for residential purposes of licensee (Ms. Rachna Tiwari). Apparently, the expenditure is in contravention of law. Also, (apparently) this is not wholly and exclusively for business purposes. Neither during the assessment proceedings, nor during present appellate proceedings, any supporting were produced to controvert this apparent proposition finding. Hence

Ramanlal Jivrajbhai Patel, Thane vs. The Income Tax Officer, Ward-1, Himatnagar

In the result, the appeal filed by the Assessee is partly allowed

ITA 515/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad11 Jun 2024AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year : 2016-17 Ramanlal Jivrajbhai Patel The Ito B-2003, Shreeji Heights Vs Ward-1 (Palm Beach Road, Navi Mumbai – Himatnagar Thane, Nerul Node –Iii So) Sector 46A, Plot No.1, 1A, 1B, 1C Thane 400 706 Maharashtra Pan: Abcpp 1551 G .. अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri B.K. Patel, Ca Revenue By : Shri Ketan Gajjar, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 06/06/2024 घोषणा क" तार"ख /Date Of Pronouncement: 11/06/2024 आदेश/O R D E R Per Makarand V. Mahadeokarthis Appeal By The Assessee Is Directed Against The Order Dated 20/02/2024 Passed By The Ld.Commissioner Of Income Tax (Appeals)- Nfac, Delhi [Hereinafter Referred To As 'The Ld. Cit(A)'] In The Matter Of Assessment Order Passed By The Assessing Officer [Hereinafter Referred To As 'The Ao’] Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As 'The Act') For The Assessment Year (Ay) 2016-17. Facts Of The Case: Ramanlal Jivrajbhai Patel Vs. Ito Asst. Year : 2016-17

For Appellant: Shri B.K. Patel, CAFor Respondent: Shri Ketan Gajjar, Sr.DR

Section 143(2)Section 143(3)Section 28Section 37(1)Section 80C

earn business income is allowable expenditure u/s. 37(1) as per Income Tax Act, 1961. Such expenditure was incurred for wholly and exclusively for business purpose only. 2. The Learned CIT(A) has erred in law and on facts as much as confirming the addition of Rs.2,70,507/- made ... incurred for earning business income, which is allowable expenditure u/s. 37(1) as per Income Tax Act, 1961. Such expenditures incurred for wholly and exclusively for business purpose only. 4.1. Therefore, it is prayed that such additions need to be deleted by passing appropriate order. Further, the assessee craves leave

DCIT-2(3)(1), Mumbai vs. Paranjapee Schemes Construction Ltd., Mumbai

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

ITA 4090/MUM/2023[2020-21]Status: DisposedITAT Mumbai31 May 2024AY 2020-21

Bench: Shri Amit Shukla & Smt Renu Jauhridcit-2(3)(1) Vs. Paranjapee Schemes Room No. 552, 5Th Floor, Construction Ltd. Aaykar Bhawan, 1, Somnath, Cts. No. 988, Mumbai-400020 Ram Mandir Road, Vile Parle (E), Near Tilak Mandir, Mumbai-400057 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaccp1941Q Appellant .. Respondent

For Appellant: Shri. Yogesh Thar &For Respondent: Shri H. M. Bhatt

Section 143Section 144Section 14ASection 250

deleting the disallowance of foreign travel expense amounting to Rs. 20,38,038/- with realizing the fact that the expenditure should be wholly and exclusively for business or profession, and the assessee had failed to validate that expenditure have been incurred wholly or exclusively for Business or profession

Bajaj Capital Limited, New Delhi vs. ACIT, Circle 4(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2598/DEL/2023[2017-18]Status: DisposedITAT Delhi31 May 2024AY 2017-18

Bench: Shri Kul Bharat & Dr.B.R.R.Kumar[Assessment Year : 2017-18] Bajaj Capital Ltd., Vs Acit, 97, Bajaj House, Nehru Place, Circle-4(2), South Delhi, New Delhi-110019. New Delhi. Pan-Aaacb1006E Appellant Respondent Appellant By Shri R.K.Sharma, Adv. Respondent By Shri Kanv Bali, Sr.Dr Date Of Hearing 16.04.2024 Date Of Pronouncement 31.05.2024

Section 143(3)Section 37(1)

expenditure and fee and subscription of INR 3,26,214/- on the ground that such expense cannot be treated for having incurred wholly and exclusively for business purposes, as same being personal in nature. 4. Aggrieved against this, the assessee preferred appeal before Ld.CIT(A), who after considering the submissions ... exclusively for the business purposes. But in the present case, the assessee failed to prove that the impugned expenditure was incurred wholly and exclusively for business purpose as stipulated u/s 37(1) of the Act. Thus, no error is committed by the lower authorities in disallowing the expenses

Highpoint Properties Pvt. Ltd., Mumbai vs. Assistant Commissioner of Income-Tax Cir. No.1(1)(2), Mumbai

ITA 4830/MUM/2023[2017-2018]Status: DisposedITAT Mumbai29 May 2024AY 2017-2018

Bench: Shri Amit Shukla & Shri Ratnesh Nandan Sahayassessment Year: 2017-18 Highpoint Properties Pvt. Ltd. Assistant Commissioner Of 41-44, Sp Centre, Income -Tax Cir. No. 1(1)(2), Minoo Desai Marg, Room No. 533, Vs. 5Th Floor, Colaba, Mumbai- 400005. Aayakar Bhavan, Maharishi Karve Road, Pan: Aabch6197D Mumbai- 400020. (Appellant) (Respondent) Present For: Assessee By : Shri Rahul Hakani, A.R. Revenue By : Shri P. D. Chougule, Addl. Cit, Sr. D.R. Date Of Hearing : 15 . 05 . 2024 Date Of Pronouncement : 29 . 05 . 2024 O R D E R Per: Ratnesh Nandan Sahay: 1. This Appeal Has Been Filed By The Appellant Against The Order Of The Ld. Cit (Appeals) Passed U/S. 250 Of The Income Tax Act [The „Act‟ In Short] Vide Din & Order No. Itba /Nfac/S/250/2023-24/1057510282(1) Dated 30/10/2023 For The Assessment Year 2017-18. 2 Highpoint Properties Pvt. Ltd.

For Appellant: Shri Rahul Hakani, A.RFor Respondent: Shri P. D. Chougule, Addl. CIT, Sr. D.R

Section 115JSection 143(2)Section 14ASection 250Section 37(1)Section 57

hearing and without appreciating that the business is set-up and had commenced in earlier year and said interest expense is incurred wholly and exclusively for business purposes and hence, the interest expense of Rs 42,71,24,908/- may be directed to be allowed as a deduction ... hearing and without appreciating that the business is set-up and had commenced in earlier year and said expense is incurred wholly and exclusively for business purposes and are necessary for maintaining the corporate structure and hence, the other expense of Rs 1,00,836/- may be allowed

DCIT Central Circle 6(1), Mumbai, Nariman Point Mumbai vs. Gnp Realty LLP, Thane

In the result, the appeal filed by the Revenue stands partly allowed

ITA 3105/MUM/2023[2021-22]Status: DisposedITAT Mumbai29 May 2024AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

For Appellant: Shri Nishit Gandhi, A.RFor Respondent: Dr. Kishor Dhule, D.R

Section 132Section 139(1)Section 142(1)Section 250

also dealt with the identical issue as to whether interest paid for delayed payment of advance tax could be considered as wholly and exclusively for business to be allowable as business expenditure. The Hon’ble Apex Court ultimately laid down the dictum that interest paid for delayed payment of advance

Mp State Mining Corporation, Bhopal vs. PCIT-1, Bhopal

In the result, appeal of the assessee is dismissed

ITA 203/IND/2023[2018-19]Status: HeardITAT Indore06 May 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanimp State Mining Corporation Pr. Cit-1 Paryavas Bhavan Block No.1, Bhopal Area Hills Vs. Mp (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcm0300K Assessee By Shri Sumit Nema, Sr. Adv. & Shri Gagan Tiwari, Ars Revenue By Shri V.K. Singh, Cit- Dr Date Of Hearing 30.04.2024 Date Of Pronouncement 06.05.2024

Section 143(3)Section 263

been accepted and allowed by the AO whereas the assesse has failed to prove that the foreign travel expenses has been incurred wholly and exclusively for business purpose of the assessee and consequently the same has been disallowed by the AO. Ld. DR has further contended that when the assessee ... upon the approval of the expenditure by the higher authorities but the assessee has to establish that the expenditure is laid out wholly and exclusively for business purpose. The assessee have not given a single detail about the purpose of the said foreign travel undertaken by the MD and what

M/S Mittal Traders, Sangrur vs. The ACIT, Central Circle, Patiala

In the result, appeal of the Assessee is partly allowed

ITA 687/CHANDI/2022[2018-19]Status: DisposedITAT Chandigarh23 Feb 2024AY 2018-19

Bench: The Appeal Is Finally Heard Or Disposed Off.

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Dharam Vir, JCIT, SR. DR

Section 143(2)

required in regular course of business of the assessee. It is hereby submitted that the amount has been advanced by the assessee wholly and exclusively for business purpose which is again used by M/s. J.R. Printing Press for its regular business transactions. Moreover, the case of the assessee

Qrg Central Hospital and Research Centre Ltd, New Delhi vs. ACIT, Circle-20(2), New Delhi

In the result, both the appeals of the assessee are allowed

ITA 4283/DEL/2018[2015-16]Status: DisposedITAT Delhi07 Feb 2024AY 2015-16

Bench: Shri Saktijit Dey & Shri M. Balaganeshqrg Central Hospital Research Vs. Acit, Centre Ltd, Circle-21(2), 909, 9Th Floor, Surya Kiran New Delhi Building, Kg Marg, Connaught Place, New Delhi (Appellant) (Respondent) Pan:Aaacq1682M Qrg Central Hospital Research Vs. Acit, Centre Ltd, Circle-20(2), 909, 9Th Floor, Surya Kiran New Delhi Building, Kg Marg, Connaught Place, New Delhi (Appellant) (Respondent) Pan:Aaacq1682M Assessee By : Dr. Rakesh Gupta, Adv Shri Deepesh Garg, Adv Revenue By: Shri S. L. Anuragi, Sr. Dr Date Of Hearing 14/11/2023 Date Of Pronouncement 07/02/2024

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri S. L. Anuragi, Sr. DR

Section 143(3)Section 15Section 23Section 28Section 37

which is a capital expenditure as well as personal expenses amounting to be Rs 2,80,788/- cannot be allowed as expenses wholly and exclusively for business purposes. ITA No.4854/Del/2017 & 4283/Del/2018 QRG Central Hospital Research Centre Ltd 4.1. Further the assessee also incurred legal expenses

Qrg Central Hospital and Research Centre Ltd, New Delhi vs. ACIT, Circle-21(2), New Delhi

In the result, both the appeals of the assessee are allowed

ITA 4854/DEL/2017[2014-15]Status: DisposedITAT Delhi07 Feb 2024AY 2014-15

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri S. L. Anuragi, Sr. DR

Section 143(3)Section 15Section 23Section 28Section 37

ACIT, Circle- 19(1), New Delhi vs. Ojas Industries (P) Ltd., New Delhi

In the result, the appeal of the assessee is allowed and the appeal of the Revenue is dismissed

ITA 4143/DEL/2017[2008-09]Status: DisposedITAT Delhi07 Feb 2024AY 2008-09

Bench: Dr. B. R. R. Kumarshri Yogesh Kumar Us

For Appellant: Sh. K.V.S.R. Krishna, CAFor Respondent: Sh. Subhra Jyoti Chakraborty, CIT-DR

Section 14ASection 37

same is incurred for business purposes. In view thereof, it is held that the payment of Rs.11,40,093/- is not incurred wholly and exclusively for business purposes. Even with respect to details of Rs.8,79,782/- furnished before the AO from which ad-hoc disallowance of Rs.5

M/S. Ojas Industries (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is allowed and the appeal of the Revenue is dismissed

ITA 3714/DEL/2017[2008-09]Status: DisposedITAT Delhi07 Feb 2024AY 2008-09

Bench: Dr. B. R. R. Kumarshri Yogesh Kumar Us

For Appellant: Sh. K.V.S.R. Krishna, CAFor Respondent: Sh. Subhra Jyoti Chakraborty, CIT-DR

Section 14ASection 37

Vdb Infra and Realty Private Limited, Bengaluru vs. Income-Tax Officer, Ward-7(1)(4), Bangalore

ITA 1017/BANG/2023[2017-18]Status: DisposedITAT Bangalore18 Jan 2024AY 2017-18

Bench: Shri George George K. & Shri Chandra Poojari

Section 250Section 270ASection 271ASection 44A

achieved a turnover of Rs. 50,85,11,249/-. It claimed various expenditure of Rs. 49,51,98,852/- including depreciation, incurred wholly and exclusively for business. This was subjected to Tax audit u/s 44AB and the audit report was filed along with the return of income. The case