Allowing the appeal of the revenue the Court held that;  it was the assessee’s own initiative to provide houses for the poor, an act of charity, done in connection with its centenary celebrations. Although the assessee may have got popularity in carrying out the noble cause, with considerable expenditure, resulting in enhanced circulation, it could not be termed as an expenditure incurred wholly or exclusively for the business of the assessee under S. 37 . The benefit derived by the business was only incidental and the assessee never intended it as a business promotion. The expenditure hence could not be allowed under S. 37 , being not one “wholly or exclusively laid out or expended for the business” of the assessee.  ( AY.1992-93)