TMI Blog2014 (1) TMI 449X X X X Extracts X X X X X X X X Extracts X X X X ..... to the credit of its employees has been recognized as a revenue expenditure – The expenditure has been certified as an expenditure not for personal expenses of the assessee and that the same is wholly and exclusively for the purpose of the business or profession of the assessee – The expenditure is deductible u/s 37 - Decided against Revenue. - Income Tax Appeal No. 39 of 2009 - - - Dated:- 26-1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dingly, added the said payment with the disclosed taxable income. Assessee having lost before the Appellate Authority went to the Tribunal and succeeded. The Tribunal held that the payment, thus made, is covered under Section 37 of the Act. Hence the present appeal. 2. Section 37 of the Act to the extent, with which we are concerned here, is as follows:- "Any expenditure (not being expendit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the payment of the premium in question is not an expenditure of the nature described in Sections 30 to 36. In order to show that the expenditure was not in the nature of capital expenditure or personal expenses of the assessee and had been spent wholly and exclusively for the purpose of business or profession, reference was drawn to Section 43B(f) of the Act, inasmuch as, Section 43B contains n ..... X X X X Extracts X X X X X X X X Extracts X X X X
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