That the Tribunal decision was set aside by the Calcutta High Court as the assessee, being in the business of manufacturing aluminium products that caused pollution in the surrounding areas, incurred expenses for drinking water supply, women and children welfare, medical services and educational support, which were backed by commercial exigency to foster harmony with the villagers in the areas surrounding the mines and necessary to ensure smooth running of the factories and to avoid industrial problems. The expenditure incurred on sundry development was wholly and exclusively for the purpose of the business. CIT v. Nicholas Piramal (India) Ltd. (I. T. A. No. 1586 of 2013, dated June 10, 2015 (Bom)(HC)  (AY.2003-04)