9911796707
TMI Blog1966 (4) TMI 3X X X X Extracts X X X X X X X X Extracts X X X X ..... or 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 admissible expenditure under section 10(2)(xv) of the Income-tax Act. The facts as they appear from the appellate order of the Tribunal and the statement of the case fall within a very narrow compass. It appears that, in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion 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 to see whether that case was applicable, the Tribunal purported to record two findings of fact relating to the case of the present assessee. One finding was that there was definitely no threat against any of the proper ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g 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 Parliamentary Board was an expenditure laid out wholly and exclusively for the purpose of the business. Every expenditure which is in the interest of a company need not necessarily be held to be an expenditure laid out wholly and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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. In the circumstances, the question referred to us is answered against the assessee and in the negative. The assessee will pay the costs of the department. Learned counsel's fee is fixed at Rs. 200. X X X X Extracts X X X X X X X X Extracts X X X X
|
