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    <title>2009 (3) TMI 225 - ITAT DELHI-E</title>
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    <description>Grants and royalty paid by a corporation were not deductible under section 37(1) because they were not incurred wholly and exclusively for carrying on business and were treated as an application of income. They were, however, allowable under section 36(1)(xii) because the assessee was constituted under the Oil Industry (Development) Act, 1974, the payments were made for authorised statutory objects, and they did not create any capital asset or enduring benefit. The special deduction provision, supported by the statutory notification governing the assessee, prevailed for these expenditure claims. The result was rejection of the section 37(1) claim and allowance under section 36(1)(xii).</description>
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      <title>2009 (3) TMI 225 - ITAT DELHI-E</title>
      <link>https://www.taxtmi.com/caselaws?id=65298</link>
      <description>Grants and royalty paid by a corporation were not deductible under section 37(1) because they were not incurred wholly and exclusively for carrying on business and were treated as an application of income. They were, however, allowable under section 36(1)(xii) because the assessee was constituted under the Oil Industry (Development) Act, 1974, the payments were made for authorised statutory objects, and they did not create any capital asset or enduring benefit. The special deduction provision, supported by the statutory notification governing the assessee, prevailed for these expenditure claims. The result was rejection of the section 37(1) claim and allowance under section 36(1)(xii).</description>
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