COMMISSIONER OF INCOME-TAX, KERALA vs MALAYALAM PLANTATION LTD.

The Supreme Court held that the estate duty paid by a resident company on behalf of its non-resident shareholders is deductible as a revenue expenditure under Section 10(2)(xv) of the Indian Income-tax Act, 1922. The Court clarified that the expression 'for the purpose of the business' encompasses a broader scope than merely earning profits, including expenses related to the preservation and protection of business assets. The High Court's decision affirming the Appellate Tribunal's ruling was upheld, allowing the deduction of estate duty in computing the company's business income.