“Section 36(2)(b)”

When there is a nexus between an expenditure and the purpose of business, incurred on grounds of commercial expediency, the Revenue cannot question its reasonableness or assume the role of the businessman to compel profit maximization. This principle applies even if the business is not that of the assessee itself.

Deduction for employee contributions to provident fund and other funds is disallowed if not paid by the due date of filing the return of income, particularly when Section 2(24)(x) and Section 36(1)(va) are considered. The omission of the second proviso to Section 43B(b) does not negate this disallowance.

Interest on borrowed capital utilized for acquiring a capital asset is capitalized until business commences. Once business is set up, this interest is deductible under section 36(1)(iii) even if the asset has not yet been put to use, accepting commercial accounting standards in the absence of contrary statutory provisions.

Interest expenditure incurred for acquiring capital assets, even if capitalized in the books, is deductible if for the purpose of business. Section 36(1)(iii) is a self-contained code regarding such deductions.

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.

No tax evasion occurs when a company pays higher expenditure to a sister concern if the sister concern also pays taxes at a higher rate. This principle applies to disallowances under section 40A(2)(b) when it can be shown that the related entity is not benefiting from a lower tax rate.

Interest paid on borrowed capital is only deductible if the loans were utilized for the assessee's business during the accounting year. Any portion of interest related to non-business purposes is not allowable as an expenditure.

A payment of bonus or commission is allowable as a business deduction under Section 36(1)(ii) unless it constitutes a distribution of profits or dividends, thereby distinguishing payments genuinely for services from those merely intended to escape taxation.