S. 37(1) : Business expenditure -Capital or revenue-Amount paid to associate company, (G4S) for providing expert advisory and other security related services and knowhow inter-alia including use of trademarks -Not allowable as business expenditure as the amount was not incurred for wholly and exclusively for business purposes ,as the assessee has not led any evidence to establish the manner in which the technical know-how as acquired from G4S had been used in its business.