47. The term ‘expenditure’ refers to any payment made by assessee, and is not confined to expenditure deductible under section 37 - Sajowanlal Jaiswal v. CIT  103 ITR 706 (Ori.). It will cover payments for acquisition of stock-in-trade or raw materials - Attar Singh Gurmukh Singh v. ITO  191 ITR 667 (SC). Even advances made for purchase of goods are covered - Kejriwal Iron Stores v. CIT  169 ITR 12 (Raj.). Payments by film distributor for acquisition of distribution rights are covered - Akash Films v. CIT  190 ITR 32 (Kar.). However, payments representing loans or their repayments are not covered - Press Note dated 2-5-1969/Letter F. No. 1(22)/69-TPL (Pt.), dated 18-4-1969. For details, see Taxmann’s Master Guide to Income-tax Rules.