A.V. Thomas And Co. Ltd. vs Commissioner Of Income-Tax on 28 January, 1986
The Supreme Court, in this decision, has reasserted the view it had expressed in CIT v. Mala-yalam Plantations Ltd. [1964] 53 ITR 140 at 150. The ratio deducible from these decisions is this: The expression " for the purpose of the business " is wider in scope than the expression " for the purpose of earning " profit. The purpose shall be for the purpose of the business, that is to say, the expenditure incurred shall be incidental to the business and the assessee shall incur it in his capacity as a person carrying on the business,