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Expenditure was general in nature and aimed at improving the practices for better fertility amongst milk animals by addressing the issues which caused infertility. The expenditure therefore was for the purpose of its business and would not be co-relatable to any tangible returns which can be expected out of such expenditure. There is therefore no reason to believe that such expenditure was revenue in nature. Tax Appeals are dismissed

Shanti Prime Publication Pvt. Ltd.

Section 37(1) of the Income-tax Act, 1961—Business expenditure - Expenditure incurred towards fertility improvement programme was general in nature and aimed at improving the practices for better fertility amongst milk animals by addressing the issues which caused infertility, therefore, the expenditure was for the purpose of its business and would not be co-relatable to any tangible returns which can be expected out of such expenditure - PR. CIT V/s GUJARAT CO-OP. MILK MARKETING FEDERATION LTD. - [2018] 6 ITCD Online 147 (GUJ)

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