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The High Court of Calcutta considered an application under section 256(1) of the Income-tax Act, 1961 regarding expenditure on free samples and technical literature by a pharmaceutical manufacturer. The court ruled that expenditure on samples was disallowed under section 37(3A) while expenditure on technical literature was allowed. The decision was based on previous rulings and the Supreme Court's judgment in Eskayef v. CIT [2000] 245 ITR 116.
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