1989 (8) TMI 137

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..... e of Rs. 16,35,150 and Rs. 45,015 u/s 37(3A). 2. The first amount represents the conveyance allowance paid to the employees of the assessee in respect of two-wheelers. The assessee claimed that this amount cannot be treated as expenditure incurred for running and maintenance of motorcar specified in sub-sec. (3B) for being disallowed under sub-sec. (3A) of sec. 37. 3. The authorities below rejec .....

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..... ch is used in conjunction with the maintenance of aircraft is to cover transport of an expensive kind and could not be extended to two-wheelers, which are economical, even by any implication. We are therefore satisfied that on a plain reading of the section as well as on a purposive approach to the problem (see CIT v. K.S. Vaidyanathan [1985] 153 ITR 11/23 Taxman 169 (Mad.) (FB)) the expenditure o .....

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..... any personnel " will not be included within the scope of advertisement and in the absence of such an exclusion it should be taken as part of advertisement expenditure. We are unable to accept this contention as it can also indicate the opposite. The specific exclusion was made when a similar expression was brought into statute book for the first time because the expression was too wide and could h .....

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