Assessee was incorporated as a Joint Venture to redevelop its railway stations and claimed it had set up business by undertaking various preliminary steps including appointing key managerial personnel, preparation of draft model development agreements and initiated process to tender financial and advisory services. Assessee claimed deduction of depreciation, preliminary expenses and employee’s remuneration. AO denied the claim by holding that no business activity was undertaken and only key personnel were engaged. High Court  held that where an entity is involved in various steps some being preliminary to setting up main substantial commercial venture linkage maybe relevant to be taken into account. Therefore even preliminary steps such as engaging in negotiation or employment of personnel would be relevant even though actual activity might not be involved. Thus, assessee set up its business as those steps were for ultimate fulfilment of its purpose and assessee’s claim for deduction was allowed.   (WP (C) No. 6782 of 2019 dt. 26-03-2019) (AY. 2013-14)