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23. We find that Hon'ble Delhi High Court in the case of Usha Micro Process Control (Supra) has observed in Para 10 as under:

Income Tax Appellate Tribunal - Delhi Cites 13 - Cited by 0 - Full Document

and also the Hon'ble Delhi High Court in the case of M/s Usha Micro Process Controls vs. CIT in ITA No.101/2000 dated 5th August, 2013.

Income Tax Appellate Tribunal - Hyderabad Cites 8 - Cited by 0 - Full Document

5. Learned counsel for the Revenue, however, submits that the decision in Usha Micro Process Controls Ltd. (supra) requires reconsideration in view of decisions of other high courts as noticed in Commissioner of Income Tax Vs. Jayaram Metal Industries, [2006] 286 ITR 403 (Kar) and Maddi Venkataraman & Co. (P) Ltd. Vs. Commissioner of Income Tax, [1998] 229 ITR 534 (SC). He submits that language of Explanation to Section 37 is quite clear and once it is held that the expenditure was incurred for any purpose, which was prohibited by law, the same is deemed not to be incurred for the purpose of business or profession.

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