Section 40(a)(i) is a Restriction on Deductibility of Expenses to the use of Business Operation

Section 40(a)(i) is a Restriction on Deductibility of Expenses to the use of Business Operation 

Section 40(a)(i) of the Income-tax Act, is a restriction on deductibility of expenses u/s 30 to 38 only to extent that expenditure claimed for the generation of revenue from business operation, otherwise not allow to deductible. In other word – expenses allow to deductible under section 40(a)(i) of the ITA, which incurred to generate revenue from business operations, not by expenses incurred on behalf of clients. - Mumbai ITAT in Interactive Avenues Private Limited vs. Deputy Commissioner of Income-tax - ITA No.: 3130/Mum/19 Assessment year: 2015-16

Click here for details judgment of Mumbai ITAT Bench –

https://www.itat.gov.in/files/uploads/categoryImage/1606883434-Interactive.pdf