S. 40A(9) applies to a "contribution" but not to "reimbursement"

Sandur Manganese and Iron Ores Ltd vs. CIT (Supreme Court)

The interpretation of Section 40A(9) of the Act clearly brings out a dichotomy between `contribution’ and `reimbursement’. Section 40A(9) of the Act was inserted by Finance Act No.2 of 1984. The Explanatory Memo to the Finance Bill, 1984 indicates the reasons why the word `contribution’ finds place in Section 40A of the Act. It appears that Section 40A(9) of the Act was inserted as a measure for combating tax avoidance.