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2019 (2) TMI 721 - KERALA HIGH COURTExpenditure incurred wholly and exclusively for the purpose of the business - allowable business expenditure - A.O. declined the claim of business expenditure on the premise that it had no connection with the business of the assessee and was not incidental to its business - principle of commercial expediency - Held that:- This Court agreed with the Tribunal's view that it was sufficient to show that the expenditure was one made voluntarily and on grounds of commercial expediency, in order to facilitate the carrying on of the business and there was no need to establish a necessity or an immediate, direct benefit. There the assessee was a collaborator of the foreign supplier and Coromandal was expected to be the assessee's customer. In the instant case, may be, PEIPL was a sister concern, or an associate concern of the assessee, but the assessee did not have any privy to Annexure D agreement, which was between M/s Cargill India Pvt.Ltd. and PEIPL. It cannot therefore be said that the expenditure was incurred by the assessee for the purpose of their business. The authorities were justified in disallowing the expenditure and we find no reason to interfere with the concurrent finding of the appellate authorities. The questions of law are answered in favour of the Revenue.
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