CIT v. Alembic Glass Industries Ltd.

112 TTJ 94Income Tax Appellate Tribunal2007#5409 most cited

What is CIT v. Alembic Glass Industries Ltd. authority for?

Expenditure incurred to establish a new unit of an existing business is considered an extension of that business, not a new business. Therefore, related expenses are allowable as revenue expenditure and depreciation on support equipment is eligible.

21

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2023.

Also referred to as

CIT v Alembic Glass Industries Ltd · 112 TTJ 94 · extension of existing business · new unit of existing business · revenue expenditure · depreciation on support equipment · eligible claim · capital expenditure vs revenue expenditure

Issues it is cited on

enduring benefitblock of assetssection 40(a)(i)comparable companiesassociated enterprisestransfer pricing adjustmentrevenue expenditureassociated enterprisecapital expenditurerule 46ainternational transactionfinal assessment order

Judgments citing CIT v. Alembic Glass Industries Ltd.

ACIT,CIRCLE-19(1), NEW DELHI vs. ONGC VIDESH LIMITED, NEW DELHI

ITA 2185/DEL/2022[2016-17]Status: DisposedITAT Delhi31 May 2023AY 2016-17

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmaacit, Vs. Ongc Videsh Limited Circle-19(1), Tower-B5, Nelson Mandela New Delhi Marg, Vasant Kinj, New Delhi Pan : Aaaco1230F (Appellant) (Respondent)

Section 143(3)Section 32Section 37(1)Section 42

…e expansion / extension or for the betterment of the product which was already being produced, and/or the improvisation made is part and parcel of the existing business, it is allowable as a revenue expenditure. In case of CIT Vs Alembic Glass Industries Ltd (112 TTJ 94), the assessee was engaged in the business of manufacturing glass and incurred certain expenses to establish a new glass manufacturing unit. It was held by the Hon'ble Gujarat High Court that the new factory did not constitute a new business but was only an establishment of a new unit of the existing business. In view of the above factual and lega…

DEPUTY COMMISSIONER OF INCOME TAX OFFICER CIRCLE-3(1)(1), BANGALORE vs. M/S FMC INDIA PRIVATE LIMITED , BANGALORE

In the result, appeal filed by assessee stands partly allowed and appeal filed by revenue stands allowed for statistical purposes

ITA 2732/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Sept 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013-14 M/S. Fmc India Pvt. The Assistant Ltd., Commissioner Of Embassy Star 1St Floor, Income Tax, No. 8 Palace Road, Circle 3(1)(1), Bangalore – 560 052. Bangalore. Vs. Pan: Aaacf4579N Appellant Respondent & Assessment Year : 2013-14 (By Revenue) Assessee By : Shri Nageswar Rao, Advocate Revenue By : Smt. S. Praveena, Cit Drp-2 Date Of Hearing : 07-07-2022 Date Of Pronouncement : 29-09-2022 Order Per Beena Pillaipresent Cross Appeals Are Filed By The Assessee & Revenue Against Order Dated 23/07/2018 Passes By The Ld.Cit(A)-3, Bangalore For Assessment Year 2013-14 On Following Grounds Of Appeal:

For Appellant: Shri Nageswar Rao, AdvocateFor Respondent: Smt. S. Praveena, CIT DRP-2
Section 250Section 37(1)

…of profit earning process and it aids the assessee to continuously improve its portfolio of products. The assessee also relied upon the decision rendered by Chandigarh bench of ITAT in the case of Glaxo Smithkline Consumer Healthcare Ltd. v. Asstt. CIT [2007] 112 TTJ 94 and also the decision rendered by Hon'ble Karnataka High Court in the case of CIT v. Bharat Earth Movers Ltd. [1985] 23 Taxman 400 and also by Chennai bench of ITAT in the case of Dy. CIT v. Magnetic Meter Systems IndiaLtd. [2012] Page 18 of 35 ITA Nos. 2611 & 2732/Bang/2018 25 taxmann.com 438. It was submitted that these expenses did not result…

M/S FMC INDIA PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, appeal filed by assessee stands partly allowed and appeal filed by revenue stands allowed for statistical purposes

ITA 2611/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Sept 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013-14 M/S. Fmc India Pvt. The Assistant Ltd., Commissioner Of Embassy Star 1St Floor, Income Tax, No. 8 Palace Road, Circle 3(1)(1), Bangalore – 560 052. Bangalore. Vs. Pan: Aaacf4579N Appellant Respondent & Assessment Year : 2013-14 (By Revenue) Assessee By : Shri Nageswar Rao, Advocate Revenue By : Smt. S. Praveena, Cit Drp-2 Date Of Hearing : 07-07-2022 Date Of Pronouncement : 29-09-2022 Order Per Beena Pillaipresent Cross Appeals Are Filed By The Assessee & Revenue Against Order Dated 23/07/2018 Passes By The Ld.Cit(A)-3, Bangalore For Assessment Year 2013-14 On Following Grounds Of Appeal:

For Appellant: Shri Nageswar Rao, AdvocateFor Respondent: Smt. S. Praveena, CIT DRP-2
Section 250Section 37(1)

…of profit earning process and it aids the assessee to continuously improve its portfolio of products. The assessee also relied upon the decision rendered by Chandigarh bench of ITAT in the case of Glaxo Smithkline Consumer Healthcare Ltd. v. Asstt. CIT [2007] 112 TTJ 94 and also the decision rendered by Hon'ble Karnataka High Court in the case of CIT v. Bharat Earth Movers Ltd. [1985] 23 Taxman 400 and also by Chennai bench of ITAT in the case of Dy. CIT v. Magnetic Meter Systems IndiaLtd. [2012] Page 18 of 35 ITA Nos. 2611 & 2732/Bang/2018 25 taxmann.com 438. It was submitted that these expenses did not result…

ADDL. CIT,SPL RNAGE-7, NEW DELHI vs. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

ITA 2379/DEL/2019[2014-15]Status: DisposedITAT Delhi05 Sept 2022AY 2014-15
Section 32(1)(ii)Section 42

…e expansion / extension or for the betterment of the product which was already being produced, and/or the improvisation made is part and parcel of the existing business, it is allowable as a revenue expenditure. In case of CIT Vs Alembic Glass Industries Ltd (112 TTJ 94), the assessee was engaged in the business of manufacturing glass and incurred certain expenses to establish a new glass manufacturing unit. It was held by the Hon'ble Gujarat High Court that the new factory did not constitute a new business but was only an establishment of a new unit of the existing business. In view of the above factual and lega…

ADDL. CIT, SPECIAL RANGE-7, NEW DELHI vs. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

ITA 158/DEL/2018[2013-14]Status: DisposedITAT Delhi05 Sept 2022AY 2013-14
Section 32(1)(ii)Section 42

…e expansion / extension or for the betterment of the product which was already being produced, and/or the improvisation made is part and parcel of the existing business, it is allowable as a revenue expenditure. In case of CIT Vs Alembic Glass Industries Ltd (112 TTJ 94), the assessee was engaged in the business of manufacturing glass and incurred certain expenses to establish a new glass manufacturing unit. It was held by the Hon'ble Gujarat High Court that the new factory did not constitute a new business but was only an establishment of a new unit of the existing business. In view of the above factual and lega…

ADDL. CIT, SPECIAL RANGE-7, NEW DELHI vs. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

ITA 7435/DEL/2017[2011-12]Status: DisposedITAT Delhi05 Sept 2022AY 2011-12
Section 32(1)(ii)Section 42

…e expansion / extension or for the betterment of the product which was already being produced, and/or the improvisation made is part and parcel of the existing business, it is allowable as a revenue expenditure. In case of CIT Vs Alembic Glass Industries Ltd (112 TTJ 94), the assessee was engaged in the business of manufacturing glass and incurred certain expenses to establish a new glass manufacturing unit. It was held by the Hon'ble Gujarat High Court that the new factory did not constitute a new business but was only an establishment of a new unit of the existing business. In view of the above factual and lega…

ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI vs. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

ITA 6281/DEL/2017[2012-13]Status: DisposedITAT Delhi05 Sept 2022AY 2012-13
Section 32(1)(ii)Section 42

…e expansion / extension or for the betterment of the product which was already being produced, and/or the improvisation made is part and parcel of the existing business, it is allowable as a revenue expenditure. In case of CIT Vs Alembic Glass Industries Ltd (112 TTJ 94), the assessee was engaged in the business of manufacturing glass and incurred certain expenses to establish a new glass manufacturing unit. It was held by the Hon'ble Gujarat High Court that the new factory did not constitute a new business but was only an establishment of a new unit of the existing business. In view of the above factual and lega…

ADDL. CIT, NEW DELHI vs. M/S ONGC VIDESH LTD.,, NEW DELHI

In the result, the appeals of the Revenue stand dismissed

ITA 2119/DEL/2017[2010-11]Status: DisposedITAT Delhi05 Sept 2022AY 2010-11
Section 32(1)(ii)Section 42

…e expansion / extension or for the betterment of the product which was already being produced, and/or the improvisation made is part and parcel of the existing business, it is allowable as a revenue expenditure. In case of CIT Vs Alembic Glass Industries Ltd (112 TTJ 94), the assessee was engaged in the business of manufacturing glass and incurred certain expenses to establish a new glass manufacturing unit. It was held by the Hon'ble Gujarat High Court that the new factory did not constitute a new business but was only an establishment of a new unit of the existing business. In view of the above factual and lega…

DCIT, NEW DELHI vs. M/S. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

ITA 3816/DEL/2015[2009-10]Status: DisposedITAT Delhi05 Sept 2022AY 2009-10
Section 32(1)(ii)Section 42

…e expansion / extension or for the betterment of the product which was already being produced, and/or the improvisation made is part and parcel of the existing business, it is allowable as a revenue expenditure. In case of CIT Vs Alembic Glass Industries Ltd (112 TTJ 94), the assessee was engaged in the business of manufacturing glass and incurred certain expenses to establish a new glass manufacturing unit. It was held by the Hon'ble Gujarat High Court that the new factory did not constitute a new business but was only an establishment of a new unit of the existing business. In view of the above factual and lega…

DCIT, NEW DELHI vs. M/S. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

ITA 3210/DEL/2014[2008-09]Status: DisposedITAT Delhi05 Sept 2022AY 2008-09
Section 32(1)(ii)Section 42

…e expansion / extension or for the betterment of the product which was already being produced, and/or the improvisation made is part and parcel of the existing business, it is allowable as a revenue expenditure. In case of CIT Vs Alembic Glass Industries Ltd (112 TTJ 94), the assessee was engaged in the business of manufacturing glass and incurred certain expenses to establish a new glass manufacturing unit. It was held by the Hon'ble Gujarat High Court that the new factory did not constitute a new business but was only an establishment of a new unit of the existing business. In view of the above factual and lega…

DCIT, NEW DELHI vs. M/S. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

ITA 3209/DEL/2014[2007-08]Status: DisposedITAT Delhi05 Sept 2022AY 2007-08
Section 32(1)(ii)Section 42

…e expansion / extension or for the betterment of the product which was already being produced, and/or the improvisation made is part and parcel of the existing business, it is allowable as a revenue expenditure. In case of CIT Vs Alembic Glass Industries Ltd (112 TTJ 94), the assessee was engaged in the business of manufacturing glass and incurred certain expenses to establish a new glass manufacturing unit. It was held by the Hon'ble Gujarat High Court that the new factory did not constitute a new business but was only an establishment of a new unit of the existing business. In view of the above factual and lega…

M/S FMC INDIA PRIVATE LIMITED ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeal of the assessee is treated as partly allowed for statistical purposes

ITA 3313/BANG/2018[2014-15]Status: DisposedITAT Bangalore25 Feb 2022AY 2014-15

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessmentyear: 2014-15

For Appellant: Shri Nageswar Rao, A.RFor Respondent: Shri Pradeep Kumar, D.R
Section 143(3)Section 35(1)(iv)Section 40

…ITA No.3313/Bang/2018 M/s. FMC India Private Ltd., Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “C’’BENCH: BANGALORE BEFORE SHRI B. R. BASKARAN, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER AssessmentYear: 2014-15 M/s. FMC India Pvt. Ltd. Deputy Commissioner of #6, 13th Main, Vasanth Nagar Income-tax Bangalore Vs. Circle 3(1)(1) Bangalore PAN NO :AAACF4579N APPELLANT RESPONDENT Appellant by : Shri Nageswar Rao, A.R. Respondent by : Shri Pradeep Kumar, D.R. Date of Hearing : 01.12.2021 Date of Pronouncement : 25.02.2022 O R D E R PERB.R. BASKARAN, ACCOUNTANT MEMBER: The assessee has filed th…

INDIA INDEX SERVICES & PRODUCTS LTD,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX 14(2)(2), MUMBAI

In the result, the appeal of the assessee is hereby ordered to be allowed

ITA 6913/MUM/2017[2012-13]Status: DisposedITAT Mumbai30 Apr 2019AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.6913/Mum/2017 (ननधधारण वर्ा / Assessment Years: 2012-13) बनधम/ M/S. India Index Services Acit-14(2)(2) Aaykar Bhawan, 4Th Floor & Products Ltd. Vs. Room No.432, M.K. Plot No. C-1, Block G, Road, Mumbai-400020. Exchange Plaza, Bandra Kurla Complex, Bandra (E) Mumbai-400051. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaaci5633A (अपीलाथी /Appellant) (प्रत्यथी / Respondent) .. Revenue By: Shri Abirama Kartikiyen (Dr) Assessee By: Shri Percy Pardiwala Sukh Sagar Syal सुनवाई की तारीख / Date Of Hearing: 05.03.2019 घोषणा की तारीख /Date Of Pronouncement: 30/04/2019 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Order Dated 01.09.2017 Passed By The Commissioner Of Income Tax (Appeals)-22, Mumbai [Hereinafter Referred To As The “Cit(A)”] Relevant To The A.Y.2012- 13. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “1. On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Erred In Confirming The Action Of The Ld. Ao In Disallowing Rs.74,43,942/- Being Research & Administration Fee Incurred For Strategic Business Planning By Treating The Same As Capital In Nature & The Reasons Assigned For Doing So Are Wrong & Contrary To The Facts & Circumstances Of The Case, Provisions Of Income Tax Act, 1961 & Rules Made Thereunder. 2. The Appellant Craves Leave To Add, Alter, Amend And/Or Modify The Above Grounds Of Appeal On Or Before The Date Of Hearing.”

For Appellant: Shri Percy PardiwalaFor Respondent: Shri Abirama Kartikiyen (DR)
Section 143(1)Section 143(2)

…124 ITR 1 (SC), (ii) CIT Vs. Carborandum Universal Ltd. (2008) 219 CTR 202 (Madras High Court), (iii) CIT Vs. Praga Tools Ltd. (1986) 157 ITR 282, (iv) DCIT Vs. Reddiff.com India Ltd. 141 TTJ 679 (Mum), (v) Glaxo Smith Kline Consumer Healthcare Ltd. Vs. ACIT, 112 TTJ 94 (Chandigarh) & CIT Vs. Kerala State Industrial Development Corporation Ltd.(1990) 182 ITR 62. On the other hand, the Ld. Representative of the Department has strongly relied upon the order passed by the CIT(A) in question. In view of the arguments advanced by the Ld. Representative of the parties and perusing the record, we noticed that the assess…

ACIT, MORADABAD vs. M/S. JUBILANT ORGANOSYES LTD., UTTAR PRADESH

The appeal is dismissed

ITA 4975/DEL/2012[2008-09]Status: DisposedITAT Delhi12 Mar 2019AY 2008-09

Bench: Smt Beena A. Pillai & Shri Prashant Maharishi

For Appellant: Shri R.M. Gupta, AdvFor Respondent: Shri J. K. Mishra, CIT DR
Section 115JSection 43(1)

…td. vs. ACIT[(2007) 165 Taxman 188 (Delhi)(MAG.)], Business Information Processing Services vs. ACIT [(2000) 73 ITD 304(Jaipur)] and ITC Classic finance Ltd. vs. DCIT [(2000) 112 Taxman 155 Mag (Cal)] Glaxo Smithkline Consumer Healthcare Ltd. Vs. ACIT [(2007) 112 TTJ 94 (Chd)], Para 44. 23. Fact shows that assessee has incurred cost of enterprise resource planning software (ERP) as per bill number 34 dated 30/9/97 of INR 9,000,000/- . Vide bill number 30/9/97 cost of implementation of above software was incurred of INR 2,600,000/-. Above two items of expenditure has been incurred by assessee in assessment year 19…

ACIT, MORADABAD vs. M/S JUBLIANT ORGANOSYS LTD., UTTAR PRADESH

The appeal is dismissed

ITA 2596/DEL/2011[2007-08]Status: DisposedITAT Delhi12 Mar 2019AY 2007-08

Bench: Smt Beena A. Pillai & Shri Prashant Maharishi

For Appellant: Shri R.M. Gupta, AdvFor Respondent: Shri J. K. Mishra, CIT DR
Section 115JSection 43(1)

…td. vs. ACIT[(2007) 165 Taxman 188 (Delhi)(MAG.)], Business Information Processing Services vs. ACIT [(2000) 73 ITD 304(Jaipur)] and ITC Classic finance Ltd. vs. DCIT [(2000) 112 Taxman 155 Mag (Cal)] Glaxo Smithkline Consumer Healthcare Ltd. Vs. ACIT [(2007) 112 TTJ 94 (Chd)], Para 44. 23. Fact shows that assessee has incurred cost of enterprise resource planning software (ERP) as per bill number 34 dated 30/9/97 of INR 9,000,000/- . Vide bill number 30/9/97 cost of implementation of above software was incurred of INR 2,600,000/-. Above two items of expenditure has been incurred by assessee in assessment year 19…

JUBILANT ORGANOSYS LTD.,NOIDA vs. ADDL. CIT, MORADABAD

The appeal is dismissed

ITA 2497/DEL/2011[2007-08]Status: DisposedITAT Delhi12 Mar 2019AY 2007-08

Bench: Smt Beena A. Pillai & Shri Prashant Maharishi

For Appellant: Shri R.M. Gupta, AdvFor Respondent: Shri J. K. Mishra, CIT DR
Section 115JSection 43(1)

…td. vs. ACIT[(2007) 165 Taxman 188 (Delhi)(MAG.)], Business Information Processing Services vs. ACIT [(2000) 73 ITD 304(Jaipur)] and ITC Classic finance Ltd. vs. DCIT [(2000) 112 Taxman 155 Mag (Cal)] Glaxo Smithkline Consumer Healthcare Ltd. Vs. ACIT [(2007) 112 TTJ 94 (Chd)], Para 44. 23. Fact shows that assessee has incurred cost of enterprise resource planning software (ERP) as per bill number 34 dated 30/9/97 of INR 9,000,000/- . Vide bill number 30/9/97 cost of implementation of above software was incurred of INR 2,600,000/-. Above two items of expenditure has been incurred by assessee in assessment year 19…

D.C.I.T.RG.8(3), MUMBAI vs. SANOFI SYNTHELABO (I) PVT. LTD., MUMBAI

In the result, all the three appeals of Revenue are dismissed

ITA 7592/MUM/2011[2006-07]Status: DisposedITAT Mumbai22 Nov 2016AY 2006-07

Bench: Sri Mahavir Singh, Jm & Ashwani Taneja, Am

Section 143(3)

…e came in second appeal before Tribunal against the order of CIT(A). 14. We find that this issue is now covered by the decision of co-ordinate bench in the case of ITAT Chandigarh bench in the case of Glaxo Smith Kline Consumer Health Care Ltd. Vs ACIT (2007) 112 TTJ 94 (CHD), wherein the Tribunal has clearly held that mere development and introduction of new varieties of product and consequent registration charges do not create any new line of business or fixed asset and hence these type of expenses are to be held as Revenue expenditure. We confirmed the findings of CIT(A) and this issue of Revenue appeal is als…

D.C.I.T. 8(3), MUMBAI vs. SANOFI SYNTHEABO (INDIA) LIMITED, MUMBAI

In the result, all the three appeals of Revenue are dismissed

ITA 6755/MUM/2011[2005-06]Status: DisposedITAT Mumbai22 Nov 2016AY 2005-06

Bench: Sri Mahavir Singh, Jm & Ashwani Taneja, Am

Section 143(3)

…e came in second appeal before Tribunal against the order of CIT(A). 14. We find that this issue is now covered by the decision of co-ordinate bench in the case of ITAT Chandigarh bench in the case of Glaxo Smith Kline Consumer Health Care Ltd. Vs ACIT (2007) 112 TTJ 94 (CHD), wherein the Tribunal has clearly held that mere development and introduction of new varieties of product and consequent registration charges do not create any new line of business or fixed asset and hence these type of expenses are to be held as Revenue expenditure. We confirmed the findings of CIT(A) and this issue of Revenue appeal is als…

ACIT RG 8(3), MUMBAI vs. SANOFI SYNTHELLABO (I) LTD, MUMBAI

In the result, all the three appeals of Revenue are dismissed

ITA 6720/MUM/2011[2004-05]Status: DisposedITAT Mumbai22 Nov 2016AY 2004-05

Bench: Sri Mahavir Singh, Jm & Ashwani Taneja, Am

Section 143(3)

…e came in second appeal before Tribunal against the order of CIT(A). 14. We find that this issue is now covered by the decision of co-ordinate bench in the case of ITAT Chandigarh bench in the case of Glaxo Smith Kline Consumer Health Care Ltd. Vs ACIT (2007) 112 TTJ 94 (CHD), wherein the Tribunal has clearly held that mere development and introduction of new varieties of product and consequent registration charges do not create any new line of business or fixed asset and hence these type of expenses are to be held as Revenue expenditure. We confirmed the findings of CIT(A) and this issue of Revenue appeal is als…

M/S. INDIAN SEAMLESS STEELS & ALLOYS LTD. vs. THE JT CIT S.R.19,

In the result, Revenue’s appeal is dismissed

ITA 2214/MUM/2005[1998-1999]Status: DisposedITAT Mumbai29 Apr 2016AY 1998-1999

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

Section 28Section 29Section 30Section 32Section 32(1)Section 43D

…3 ITR 11 (P&G); ii) DCIT v/s Max India Ltd., [2006] 105 TTJ 1002; iii) M/s. Cisco Systems (I) Pvt. Ltd. v/s ACIT, ITA no.431/Bang./2010, dated 28.4.2011; iv) CIT v/s ACL Wireless Ltd. [2013] 361 ITR 210 (Del.); v) Glaxo Smith Kline Consumer Healthercare Ltd., 112 TTJ 94 (Chd.); vi) Metalman Auto Pvt. Ltd., 74 ITD 327 (Chd.); vii) Rediff.com India Ltd., 141 TTJ 679 (Mum.). 55. Further, the learned Authorised Representative submitted, unlike Companies Act, there is no concept of deferred revenue expenditure in the Income Tax Act. The expenditure can either be revenue or capital. In assessee’s case, since the expen…

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CIT v. Alembic Glass Industries Ltd. (112 TTJ 94) — Cited in 21 Judgments | BharatTax