JUDGMENT K.S. Puttaswamy, J.—In these separate but identical references made under section 256(1) of the Income Tax Act, 1961 ("the Act"), the Income Tax Appellate Tribunal, Bangalore Bench, Bangalore ("the Tribunal"), at the instance of the assessee, has referred the following question of law for the opinion of this court for the three assessment years of the assessee : "Whether, on the facts and in the circumstances of the case, the assessee was not entitled to the allowance under section 35B of the Income Tax Act in respect of expenditure of Rs. 30,900 for the assessment year 1977-78 ?" 2. In order to appreciate the question referred to us, it is necessary to notice, in the first instance, the facts as found by the Tribunal. 3. The assessee is a wholly owned Government company of the Government of Karnataka. The assessee has been incorporated, inter alia, with the primary object of carrying on business "to aid, counsel, assist, finance, protect and promote the interests of small industries in Karnataka, whether owned or run by the Government, a statutory body, a company, firm or an individual, or to provide them with capital, credit, means, resources and technical and managerial assistance for the prosecution of their work and business, to enable them to develop and improve their methods of manufacture, management and marketing and their technique of production" to which all other objects are incidental and ancillary. 4. For the assessment years 1975-76, 1976-77 and 1977-78 relevant to the previous years ending on June 30, 1974, June 30, 1975, and June 30, 1976, the assessee incurred various amounts of expenditure on the foreign travels of its chairman and managing director and payment of rent at such export exhibitions for the aforesaid assessment years. In its returns filed under the Act before the Income Tax Officer, Company Circle-IV, Bangalore, the assessee claimed "weighted deduction" on the aforesaid amounts under section 35B of the Act, and the Income Tax Officer by separate but identical orders, made on different dates, disallowed the same. Aggrieved by the said orders, the assessee filed appeals before the Appellate Assistant Commissioner of Income Tax, Range-III, Bangalore, who by separate but identical orders made on different dates, dismissed them. Aggrieved by the said orders, the assessee filed appeals before the Appellate Assistant Commissioner of Income Tax, Range-III, Bangalore, who by separate but identical orders made on different dates, dismissed them. Aggrieved by the said orders of the Income Tax officer and the Appellate Assistant Commissioner, the assessee filed second appeals before the Tribunal which by its common order made on February 22,1978, dismissed then. Hence, these references. 5. Sri S. P. Bhat, learned counsel for the assessee, contends that the expenditure incurred by his client was for carrying on the business activities stipulated in its memorandum of association and the same was entitled to be allowed "weighted deduction" under section 35B(1)(b)(i) of the Act. 6. Sri K. Srinivasan, learned senior standing counsel for the Income Tax Department, appearing for the Revenue, contends that the expenditure incurred by the assessee was not in the course of export promotion of the business of the assessee and, therefore, it was not entitled to claim weighted deduction" under the Act. 7. We have earlier noticed the principal object with which the assessee had been incorporated and is carrying on its business. The objects of the assessee's business do not enable it to undertake export or marketing of goods outside India as one of its business at all. 8. Section 35B(1)(b)(i) of the Act, on the construction of which the claim made by the assessee turns, reads thus : "35B. (1)(a) Where an assessee, being a domestic company or a person (other than a company) who is resident in India, has incurred after the 29th day of February, 1968, but before the 1st day of March, 1983, whether directly or in association with any other person, any expenditure (not being in the nature of capital expenditure or personal expenses of the assessee) referred to in clause (b), he shall, subject to the provisions of this section, be allowed a deduction of a sum equal to one and one-third times the amount of such expenditure incurred during the previous year : Provided that in respect of the expenditure incurred after the 28th day of February, 1973, but before the 1st day of April, 1978, by a domestic company, being a company in which the public are substantially interested, the provisions of this clause shall have effect as if for the words 'one and one-third times', the words 'one and one-half times' had been substituted. (b) The expenditure referred to in clause (a) is that incurred wholly and exclusively on - (i) advertisement or publicity outside India in respect of the goods, services or facilities which the assessee deals in or provides in the course of his business." 9. The heading of a section gives a clue for understanding the section though it cannot control the plain language of the section. The heading of the section states that it regulates "export markets development allowance" as elaborately set out in that section. 10. The main section, viz., section 35B(1)(a), enumerates the persons qualified to claim the allowance, the period during which the same can be claimed and the nature of expenditure on which the same can be claimed. Then the said section that follows, viz., section 35B(1)(b), enumerates the expenditure on which the allowance of weighted deduction, as it is called, can be allowed. Even according to the assessee, its case attracts section 35B(1)(b)(i) of the Act only and not any other clause. But the very clause on which the assessee relies stipulates that the same should be in the course of its business. The expenditure on advertisement or publicity outside India must be incurred in respect of goods, services or facilities which the assessee deals in or provides in the course of its business and no other. In other words, the expenditure must be related to the business carried on by the assessee. On our earlier finding, it is clear that the claim of the assessee does not at all attract section 35B(1)(b)(i) of the Act and the same had been rightly disallowed by the Tribunal. We must, therefore, answer the question in the affirmative. 11. In the light of our above discussion, we answer the question referred to us in the affirmative, against the assessee and in favour of the Revenue. But, in the circumstances of the case, we direct the parties to bear their own costs.