Unsupported expense claims and interest deduction ceiling cannot be avoided by reclassifying deductions under a general provision.

Unverified expenditure claims for workers' payments, miscellaneous expenses, legal charges and refreshments were disallowed because the assessee produced no vouchers, details or other supporting material, and the factual findings on lack of proof were not disturbed in revision. Interest deduction was also confined by the specific ceiling provision, and the claim could not be recharacterised under a general deduction provision to bypass that limit. Where a deduction falls within a special restricting clause, alternative labelling does not avoid the statutory ceiling. The revision therefore failed, with both the disallowance of unsupported expenses and the restriction on interest deduction sustained.

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Issues: (i) Whether the disallowance of the claims for workers' payments, miscellaneous expenses, legal charges and refreshment charges was justified for want of supporting material; (ii) Whether the deduction for interest was correctly restricted by applying the ceiling under section 5(k) and could be claimed instead under section 5(e).

Issue (i): The disputed expenditure claims were examined by the Tribunal and the lower authorities, and the assessee failed to produce vouchers, details, or other material to substantiate the alleged payments. The Tribunal's factual findings on the unsustainability of unverified claims could not be interfered with in revision.

Conclusion: The disallowance of these expenditure claims was upheld against the assessee.

Issue (ii): Interest claimed as deduction had been restricted under the ceiling provision in section 5(k). The claim could not be shifted to section 5(e), since section 5(e) is the general provision and items falling within section 5(k) do not escape the statutory ceiling merely by alternative characterization. No material was shown to establish that the interest fell outside section 5(k) or that the borrowings were for purposes bringing the claim within section 5(e).

Conclusion: The restriction under section 5(k) was correctly applied and the excess interest deduction was rightly disallowed.

Final Conclusion: The revision failed as the Tribunal's findings on the unsubstantiated expenditure claims and the statutory ceiling on interest deduction were sustained.

Ratio Decidendi: A claim falling within a specific deduction-limiting provision cannot be reclassified under a general deduction provision to avoid the statutory ceiling, and unsubstantiated expenditure claims are not open to interference when the fact-finding authority records adverse findings for want of proof.

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