S. 40 (a)(iib) :Amounts not deductible- Fee- Tax – Gallonge fee , licence fee and shop rental (KIST ) with respect to EL-9 and E.L -I licence granted will fall with in the purview of section and hence disallowable -Surcharge on Sales tax and turnover tax is not fee or charge hence not disallowable – Interpretation of taxing statutes – Same statute using different terms and expressions – Must be taken to refer to distinct and different things . [ S. 37(1)), Kerala Abkari Act, 1077 (M.E.) S. 18 , Kerala Foreign Liquor Rules , 1953 , R. 15A ]