‘Distributable Surplus’ paid to India Subsidiary of DIAGEO was application of income; not deductible

IT : Distributable surplus paid to Indian subsidiary of UK based company DIAGEO Plc. under agreement whereby assessee (an Indian entity) agreed to manufacture and sell alcoholic products under control and supervision of DIAGEO India, was nothing but an 'application of income' by assessee and same was not an allowable expenditure under section 37(1).

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