TMI Blog1966 (4) TMI 3X X X X Extracts X X X X X X X X Extracts X X X X ..... incurred for the purpose of the business - - - - - Dated:- 28-4-1966 - Judge(s) : V. BHARGAVA., S. C. MANCHANDA. JUDGMENT The judgment of the court was delivered by V. BHARGAVA C. J.-The question referred for our opinion is whether, on the facts and in the circumstances of the case, the payment of Rs. 56,000 made to the Congress Parliamentary Board for the General Elections was an admis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... act whether this contention was accepted by it or not. On the other hand, the Tribunal, thereafter, immediately proceeded to deal with the case of Morgan v. Tate Lyle Ltd., where a certain expense incurred in connection with political propaganda was allowed as an expenditure legitimately deductible on the ground of being wholly and exclusively for the purpose of the business. While endeavouring ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m the recitation of the facts given by us above that the contention of the assessee was confined to a general assertion that it was in the interest of the company to keep the ruling party in power because of the changing pattern of the economic structure of society. This is the only one assertion on which the assessee relied in order to claim that this contribution to the U. P. Congress Parliament ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... this contribution to the Congress Parliamentary Board and expenditure incurred for the purpose of the business. When there is no direct nexus between the business of the company and this contribution, it appears to be impossible to hold that the assessee-company discharged the burden of proof which lay on it to show that this expenditure was wholly and exclusively for the purpose of the business. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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