The Respondent assessee had claimed deduction under the head community development expenditure  for providing  street lights  on the road , ambulance for meeting medical emergencies , developing public garden for residence of the village where the factory is situated . The Assessing Officer disallowed the expenditure on the ground that the same are not incurred wholly and exclusively  for the purpose of  Respondents’ business  . The CIT(A) up held the order the AO. On appeal Tribunal  following the decision in CIT v. Madras Refineries Ltd (2004 )  266 ITR 70 ( Mad)( HC) allowed the appeal on the ground that the concept of business is not static and over a period of time , it would include within its fold the care and concern for the society at large which would result in a good will being created in its favour leading  to better business .  Accordingly  the expenditure is allowed as allowable business expenditure . On appeal by the Revenue the High Court affirmed the order of the Tribunal . (ITA No. 1686 of 2013 dt . 10 -7 2015 )( AY. 1996 -97 )