Dismissing the appeal of the revenue the Court held that, surrender of oil blocks before commencement of commercial production would be treated as surrender for claiming deduction of oil exploration expenditure and eligible deduction . Court also observed that S. 42 recognizes the risks of the business of oil exploration which activity is capital intensive and high in risk of entire expenditure not yielding any fruitful result. Entire purpose or enactment would be destroyed if the rigid interpretation of the revenue is accepted.  (AY. 2008 -09)