Section 37 of the Income Tax Act, 1961 — Business Expenditure — When the payment of countervailing duty was not in dispute the payment was otherwise  allowable deduction and could not be added to the income of assessee merely because the assessee had claimed a refund. the AO was under a duty and obligation to assess the  actual and correct income in accordance with the provisions of the Act while acting as quasi judicial authority and not to take advantage of any mistake or the entries made in the books of account — Trust Marketing vs. Assistant Commissioner of income tax[2019] 76 ITR (Trib) 119 (Jaipur)