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Microlesson · 5-min read

Residuary Expenses [Section 37]

## Residuary Expenses — Section 37

### Idea

Section 37 is the catch-all deduction. If a business expense is not specifically covered by Sections 30 to 36, it may still be deductible under Section 37 — provided it passes the general tests.

### Conditions for allowance

The expenditure must be:

  • Not already covered under Sections 30–36;
  • Wholly and exclusively for business/profession purposes;
  • Not personal and not capital in nature;
  • Incurred after the business is set up.

### Express disallowances

  • Provisions/reserves for contingent liabilities — not allowed.
  • Expenses related to offences or prohibited acts (e.g., bribes) — not allowed.
  • Expenditure to settle proceedings for contraventions under SEBI, SCRA, Depositories Act, Competition Act — not allowed.
  • Business losses (embezzlement, theft, destruction of assets) — not allowed under S.37 (these are dealt with elsewhere).
  • Reasonableness is irrelevant — the A.O. cannot disallow merely because the expense seems high (except under 40A(2)).

### Key clarifications

  • Keyman insurance premium on a policy taken by the firm in the name of a partnerallowed (Circular 38/2016).
  • Freebies to doctors by pharma companies → not allowed (prohibited under IMC Regulations).
  • CSR expenditure (S.135 Companies Act) → not allowed as a deduction. However, contributions referred to in Section 35 are allowed.
  • Advertisement in a souvenir/brochure/tract published by a political partynot allowed u/s 37(2B). For companies, it is treated as a contribution to a political party and allowed instead under Section 80GGB.

Worked example

### Example 1

Political party advertisement.

A company spends ₹2,00,000 on an advertisement in a souvenir published by a political party.

  • Under PGBP: Disallowed u/s 37(2B).
  • However, it is treated as a contribution to a political party and is allowable to the company under Section 80GGB (deduction from Gross Total Income), provided not paid in cash.

⚠️ Common exam mistakes

  • Allowing CSR expenditure under Section 37 — it is specifically disallowed (only Section 35 contributions are allowed).
  • Disallowing an expense merely because it appears 'unreasonable' — reasonableness is irrelevant under S.37 (only 40A(2) tests reasonableness).
  • Allowing freebies given by pharma companies to doctors — barred under IMC Regulations.
  • Claiming a deduction for capital or personal expenditure under the residuary section.
  • Forgetting that political-party advertisement, though disallowed under PGBP, may be claimed by a company under 80GGB.
Reference: Section 37
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