Held that  as the agro products of the assessee were sold under the brand name “Sardar”, which was very popular amongst the farming community, the assessee’s contention that the statue of Sardar Vallabhai Patel would significantly enhance the brand value of its products and improve sales and exports, was justified. The expenditure was, therefore, wholly and exclusively for the purpose of business on account of commercial expediency and, accordingly, was allowable under section 37. Moreover, the funding was for the State Government.  Relied on Dy.CIT v. Gujarat Narmada Valley Fertilizers Co Ltd (Tax Appeal Nos  770 of 1999, 77, 78 of 2008, dated May 6, 2011. (AY. 2011-12)