ROAD INFRASTRUCTURE DEVELOPMENT COMPANY OF RAJASTHAN LTD.,JAIPUR vs. ACIT, CIRCLE 6, JAIPUR, CENTRAL REVENUE BUILDING, NEAR STATUE CIRCLE

ITA 1425/JPR/2025Status: DisposedITAT Jaipur14 August 2026AY 2014-158 pages
AI SummaryPartly Allowed

What were the facts?

The assessee, a joint venture company engaged in highway development, appealed against disallowances made by the AO and confirmed by the CIT(A). These disallowances pertained to share capital expenses, expenses under Section 14A, and socio-economic expenses.

What did the Tribunal hold?

The tribunal held that the share capital expenses were eligible for amortisation under Section 35D, the disallowance under Section 14A was unsustainable as no exempt income was earned, and the socio-economic expenses were allowable business expenditures. The penalty proceedings were dismissed as premature.

What were the issues?

Whether expenses for increasing authorised share capital are amortisable under Section 35D, whether disallowance under Section 14A is permissible without exempt income, and if socio-economic expenses incurred under contractual obligations are allowable business expenses.

Which sections of the Income-tax Act were involved?

Section 35D,Section 14A,Section 37(1),Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, JAIPUR

Before: Shri T.R. Senthil Kumar & Shri Prakash

PER : PRAKASH, ACCOUNTANT MEMBER:-

This appeal by the assessee is directed against the order of the learned

1.

Additional/Joint Commissioner of Income Tax (Appeals), Agra [hereinafter referred to as “the Addl./JCIT(A)”] dated 14.08.2025 for the Assessment Year 2014-15, arising out of the assessment order dated 27.12.2016 passed by the Assistant Commissioner of Income Tax, Circle-06, Jaipur [hereinafter referred to as “the AO”] under section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”).

ITA No. 1425-JPR-2025 Road Infrastructure Development Company of Rajasthan Ltd.

2.

The grounds of appeal

The order continues below.

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