While allowing the deduction the Tribunal held that held that so long as the expenses have been incurred wholly and exclusively for the purpose of business, whether necessary or not are to be allowed as expenditure.  Relied on CIT v. ChandulalKeshavlal& Co. 38 ITR 601 (SC)  and Sasoon J. David & Co. v. CIT 180 ITR 261 (SC)  wherein it has been held that the expenditure incurred voluntary on account of commercial expediency and wholly and exclusively for the purpose of trade, then it is allowable expenditure. The Court in the above case observed that it is pertinent to note that the words “wholly and exclusively” used in S.  37 of the Act does not mean “necessarily”. Thus, it is for the assessee to decide whether the expenditure should be incurred in the course of his business and once it is found that it is incurred wholly and exclusively for the purposes of business, then it is deductible under S.  37 of the Act. It further records that it is relevant to note that an attempt was made to introduce the word “necessity” in S.  37 of the Income Tax Bill of 1961. However, this had led to public protest and resulted in dropping the word “necessity” when the Income Tax bill of 1961 was passed into the Income Tax Act, 1961. Thus, the view of the Tribunal on this issue cannot be faulted as it is in accord with the Supreme Court decisions referred to hereinabove.Dismissing the appeal of the revenue the Court  held that  sales promotion expenses  is held to be allowable as business expenditure.  High Court affirmed the order of Tribunal. (AY. 2010-11)