" In Badridas Daga vs Commissioner of Income tax,(2) Venkatarama Aiyar, J., observed that whether the expenditure is admissible or not will depend upon whether it can be said to arise out of the carrying on of the business and be incidental to it, and this was reaffirmed by this Court in a later judgment in Commissioner of Income tax, Bombay vs Abdullabhai Abdulkadar.(3) (1) ; (2) ; I.T.R. 10 (3) ; 326 In a recent judgment of this Court Commissioner of Income tax, Kerala vs Malayalam Plantations Ltd.(1) certain amounts paid as estate duty under section 84 of the , by a resident company incorporated outside India on the death of shareholders not domiciled in India, were sought to be deducted under section 10(2) (xv) as expenditure laid out or expended wholly and exclusively for the purposes of the business.