CIT v. Citi Financial Consumer Finance Ltd.

335 ITR 29High Court2011#1464 most cited

What is CIT v. Citi Financial Consumer Finance Ltd. authority for?

Customer acquisition costs and advertisement expenditures are treated as revenue expenditures, not deferred expenditures, as there is no general concept of deferred expenditure for such items under Income Tax Law.

78

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2025.

Also referred to as

CIT v. Citi Financial Consumer Finance Ltd. · 335 ITR 29 · revenue expenditure · deferred expenditure · customer acquisition cost · advertisement expenditure · section 36(1) · deductibility of expenses · capital expenditure

Sections most often in play

Section 143(3)Section 143(1)Section 144C(1)Section 144C(5)Section 194JSection 2(47)Section 234BSection 260A

Issues it is cited on

section 80ib(2)section 11bsection 80ib(4)section 36(l)(iii)section 36(l)initial assessment yearsection 43(1)sanctioning authoritysection 80hhcenduring benefitsection 80ibsection 80i

Judgments citing CIT v. Citi Financial Consumer Finance Ltd.

TATA TELESERVICES LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 25(1), DELHI

In the result, the appeal of the assessee is allowed

ITA 2549/DEL/2024[2017-18]Status: DisposedITAT Delhi27 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.2549/Del./2024, A.Y. 2017-18 Tata Teleservices Limited Assistant Commissioner Of Jeevan Bharati Tower-1, Income Tax, Circle-25(1), 10Th Floor, Vs. C. R. Building, I. P. Estate, 24, Connaught Circus New Delhi New Delhi Pan: Aaact2438A (Appellant) (Respondent) Appellant By Sh. Salil Kapoor, Advocate Ms. Ananya Kapoor, Advocate & Sh. Shivam Yadav, Advocate Respondent By Sh. Dayainder Singh Sidhu, Cit-Dr Date Of Hearing 30/07/2025 Date Of Pronouncement 27/10/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal Of The Assessee For Assessment Year (‘Ay’) 2017-18 Is Directed Against The Order Dated 29.03.2024 Of The Commissioner Of Income Tax (Appeals), Nfac, New Delhi [‘Cit(A)’].

Section 142(1)Section 143(3)Section 35DSection 37(1)

…expressly included under the provisions of any specific section under the Act." The assessee has placed reliance on the following: Taparia Tools Limited versus Joint Commissioner of Income Tax Commissioner of Income Tax Vs Citi Financial Consumer Finance Ltd (335 ITR 29) (Del HC) C.I.T. V/s. ACC Ltd. [172 ITR 257] (SC) Hindustan Commercial Bank Ltd. [21 ITR 353] (HC) R.K. Swamy Advertising Associates (P) Ltd. [44.ITD 99] [Mad ITAT] The assessee has made the following conclusion; "Therefore, expense incurred by TTSL with respect to customer acquisition cost cannot be deferred as there is no concept of deferred exp…

SPANDANA SPHOORTY FINANCIAL LIMITED,HYDERABAD vs. ACIT., CIRCLE 3(2), HYDERABAD

Accordingly, the addition of Rs.11,44,51,818/- (supra) made by the\nAO, which, thereafter, had been sustained by the CIT(A), is vacated.\nThe Grounds of appeal Nos.3.1 to 3.4 are allowed in terms o...

ITA 821/HYD/2025[2017-18]Status: DisposedITAT Hyderabad17 Oct 2025AY 2017-18
Section 143(3)Section 145Section 69A

…per the mandate of law, had\nrelied upon the judgment of the Hon'ble Supreme Court in the case of\nTaparia Tools Ltd. vs. JCIT (2015) 372 ITR 605 (SC) and that of the\nHon'ble High Court of Delhi in the case of CIT v. Citi Financial\nConsumer Fin. Ltd (2011) 335 ITR 29 (Delhi). Also, the Ld. AR had\npressed into service the order of the coordinate Bench of the Tribunal,\ni.e., ITAT, Kolkata in the case of Magma Fincorp Limited vs. DCIT,\nCircle-8(1), Kolkata (2017) 82 taxmann.com 481 (Kolkata).\n13. Per contra, the Learned Commissioner of Income Tax-\nDepartmental Representative (for short, “Ld. CIT-DR") at the\…

DCIT, NEW DELHI vs. M/S. VODAFONE ESSAR DIGILINK LTD., NEW DELHI

ITA 1158/DEL/2015[2010-11]Status: DisposedITAT Mumbai14 Oct 2025AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Ketan Ved & Shri Ninad PatadeFor Respondent: Shri Pankaj Kumar
Section 143(1)Section 143(3)Section 144C(1)Section 144C(5)Section 92C

…. 10. Having considered the arguments from both the sides and perused the relevant material on record, we find that this issue is no more res integra in view of the judgment of the Hon'ble Delhi High Court in CIT v. Citi Financial Consumer Finance Ltd. [2011] 335 ITR 29/[2012] 20 taxmann.com 452 in which advertisement expenditure has been treated as revenue. In view of the judgment of the Hon'ble jurisdictional High Court, which has been relied by the DRP, we are of the considered opinion that no interference is warranted in the impugned order on this score. This ground is dismissed.” (Emphasis Supplied) 5.5. The…

VODAFONE DIGILINK LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

ITA 1073/DEL/2015[2010-11]Status: DisposedITAT Mumbai14 Oct 2025AY 2010-11
Section 143(1)Section 144C(1)Section 144C(5)Section 92C

…. Having considered the arguments from both the sides and\nperused the relevant material on record, we find that this issue\nis no more res integra in view of the judgment of the Hon'ble\nDelhi High Court in CIT v. Citi Financial Consumer Finance Ltd.\n[2011] 335 ITR 29/[2012] 20 taxmann.com 452 in which\nadvertisement expenditure has been treated as revenue. In\nview of the judgment of the Hon'ble jurisdictional High Court,\nwhich has been relied by the DRP, we are of the considered\nopinion that no interference is warranted in the impugned order\non this score. This ground is dismissed.” (Emphasis Supplied)\n\n…

ACIT, CIRCLE 22(2), NEW DELHI vs. SNAPDEAL LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 184/DEL/2023[2017-18]Status: DisposedITAT Delhi26 Apr 2024AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2017-18

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Dharamvir Singh, CIT-DR

…romotion 8 expenditure should normally be treated as revenue expenditure unless there are special circumstances to hold that said expenditure was capital in nature. The gist of these decisions are discussed as under: (i) Citi Financial Consumer Finance Ltd. (335 ITR 29) (in this case SLP filed by the department also stands dismissed) "14. Applying the aforesaid principle to the facts of this case, it clearly emerges that the expenditure on publicity and advertisement is to be treated as revenue in nature allowable fully in the year in which it was incurred. Concededly, there is no advantage which has accrued to…

DCIT CENTRAL CIRCLE-2(4) , MUMBAI vs. RUSTOMJEE EVERSHINE JOINT VENTURE , MUMBAI

In the result, the appeals filed by the revenue for AY 2013-14 &

ITA 1825/MUM/2022[2014-15]Status: DisposedITAT Mumbai31 Jul 2023AY 2014-15

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.1349/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2013-14) Dcit, Central Circle-2(4) बिधम/ Rustomjee Evershine Room No. 802, 8Th Floor, Joint Venture Vs. Prathishtha Bhavan, M. K. Global City, Narangi Road, Churchgate, Mumbai- Bypass Road, Close To 400020. Viva College, Virar (W), Virar-401303. Cross Objection No. 27/Mum/2023 Arising Out Of I.T.A. No.1349/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2013-14) Rustomjee Evershine Joint बिधम/ Dcit, Central Circle-2(4) Room No. 802, 8Th Floor, Venture Vs. Global City, Narangi Prathishtha Bhavan, M. K. Bypass Road, Close To Viva Road, Churchgate, College, Virar (W), Virar- Mumbai-400020. 401303. आयकर अपील सं/ I.T.A. Nos.1824 & 1825/Mum/2022 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2014-15) Dcit, Central Circle-2(4) बिधम/ Rustomjee Evershine Room No. 802, 8Th Floor, Joint Venture Vs. Prathishtha Bhavan, M. K. Global City, Narangi Road, Churchgate, Mumbai- Bypass Road, Close To 400020. Viva College, Virar (W), Virar-401303. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaaar7687M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Naresh Kumar Revenue By: Shri P. D. Chougule (Addl. Cit) सुनवाई की तारीख / Date Of Hearing: 25/05/2023 घोषणा की तारीख /Date Of Pronouncement: 31/07/2023

For Appellant: Shri Naresh KumarFor Respondent: Shri P. D. Chougule (Addl. CIT)

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI ABY T. VARKEY, JM AND SHRI S. RIFAUR RAHMAN, AM आयकर अपील सं/ I.T.A. No.1349/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2013-14) DCIT, Central Circle-2(4) बिधम/ Rustomjee Evershine Room No. 802, 8th Floor, Joint Venture Vs. Prathishtha Bhavan, M. K. Global City, Narangi Road, Churchgate, Mumbai- Bypass Road, Close to 400020. Viva College, Virar (W), Virar-401303. Cross Objection No. 27/Mum/2023 Arising out of I.T.A. No.1349/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2013-14) Rustomjee Evershine Joint बिधम/ DCIT, Central Circle-2(4) Room No. 802, 8…

DCIT CENTRAL CIRCLE-2(4) , MUMBAI vs. RUSTOMJEE EVERSHINE JOINT VENTURE , MUMBAI

In the result, the appeals filed by the revenue for AY 2013-14 &

ITA 1824/MUM/2022[2016-17]Status: DisposedITAT Mumbai31 Jul 2023AY 2016-17

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.1349/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2013-14) Dcit, Central Circle-2(4) बिधम/ Rustomjee Evershine Room No. 802, 8Th Floor, Joint Venture Vs. Prathishtha Bhavan, M. K. Global City, Narangi Road, Churchgate, Mumbai- Bypass Road, Close To 400020. Viva College, Virar (W), Virar-401303. Cross Objection No. 27/Mum/2023 Arising Out Of I.T.A. No.1349/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2013-14) Rustomjee Evershine Joint बिधम/ Dcit, Central Circle-2(4) Room No. 802, 8Th Floor, Venture Vs. Global City, Narangi Prathishtha Bhavan, M. K. Bypass Road, Close To Viva Road, Churchgate, College, Virar (W), Virar- Mumbai-400020. 401303. आयकर अपील सं/ I.T.A. Nos.1824 & 1825/Mum/2022 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2014-15) Dcit, Central Circle-2(4) बिधम/ Rustomjee Evershine Room No. 802, 8Th Floor, Joint Venture Vs. Prathishtha Bhavan, M. K. Global City, Narangi Road, Churchgate, Mumbai- Bypass Road, Close To 400020. Viva College, Virar (W), Virar-401303. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaaar7687M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Naresh Kumar Revenue By: Shri P. D. Chougule (Addl. Cit) सुनवाई की तारीख / Date Of Hearing: 25/05/2023 घोषणा की तारीख /Date Of Pronouncement: 31/07/2023

For Appellant: Shri Naresh KumarFor Respondent: Shri P. D. Chougule (Addl. CIT)

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI ABY T. VARKEY, JM AND SHRI S. RIFAUR RAHMAN, AM आयकर अपील सं/ I.T.A. No.1349/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2013-14) DCIT, Central Circle-2(4) बिधम/ Rustomjee Evershine Room No. 802, 8th Floor, Joint Venture Vs. Prathishtha Bhavan, M. K. Global City, Narangi Road, Churchgate, Mumbai- Bypass Road, Close to 400020. Viva College, Virar (W), Virar-401303. Cross Objection No. 27/Mum/2023 Arising out of I.T.A. No.1349/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2013-14) Rustomjee Evershine Joint बिधम/ DCIT, Central Circle-2(4) Room No. 802, 8…

DCIT CENTRAL CIRCEL-2(4), MUMBAI vs. RUSTOMJI EVERSHINE JOINT VENTURE, MUMBAI

In the result, the appeals filed by the revenue for AY 2013-14 &

ITA 1349/MUM/2022[2013-2014]Status: DisposedITAT Mumbai31 Jul 2023AY 2013-2014

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.1349/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2013-14) Dcit, Central Circle-2(4) बिधम/ Rustomjee Evershine Room No. 802, 8Th Floor, Joint Venture Vs. Prathishtha Bhavan, M. K. Global City, Narangi Road, Churchgate, Mumbai- Bypass Road, Close To 400020. Viva College, Virar (W), Virar-401303. Cross Objection No. 27/Mum/2023 Arising Out Of I.T.A. No.1349/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2013-14) Rustomjee Evershine Joint बिधम/ Dcit, Central Circle-2(4) Room No. 802, 8Th Floor, Venture Vs. Global City, Narangi Prathishtha Bhavan, M. K. Bypass Road, Close To Viva Road, Churchgate, College, Virar (W), Virar- Mumbai-400020. 401303. आयकर अपील सं/ I.T.A. Nos.1824 & 1825/Mum/2022 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2014-15) Dcit, Central Circle-2(4) बिधम/ Rustomjee Evershine Room No. 802, 8Th Floor, Joint Venture Vs. Prathishtha Bhavan, M. K. Global City, Narangi Road, Churchgate, Mumbai- Bypass Road, Close To 400020. Viva College, Virar (W), Virar-401303. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaaar7687M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Naresh Kumar Revenue By: Shri P. D. Chougule (Addl. Cit) सुनवाई की तारीख / Date Of Hearing: 25/05/2023 घोषणा की तारीख /Date Of Pronouncement: 31/07/2023

For Appellant: Shri Naresh KumarFor Respondent: Shri P. D. Chougule (Addl. CIT)

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI ABY T. VARKEY, JM AND SHRI S. RIFAUR RAHMAN, AM आयकर अपील सं/ I.T.A. No.1349/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2013-14) DCIT, Central Circle-2(4) बिधम/ Rustomjee Evershine Room No. 802, 8th Floor, Joint Venture Vs. Prathishtha Bhavan, M. K. Global City, Narangi Road, Churchgate, Mumbai- Bypass Road, Close to 400020. Viva College, Virar (W), Virar-401303. Cross Objection No. 27/Mum/2023 Arising out of I.T.A. No.1349/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2013-14) Rustomjee Evershine Joint बिधम/ DCIT, Central Circle-2(4) Room No. 802, 8…

THE DY. COMMISSIONER OF INCOME TAX, JAMMU vs. M/S. FIL INDUSTRIES LTD, SRINAGAR

In the result appeal of the assessee ground no 4 to 4

ITA 471/ASR/2015[2010-11]Status: DisposedITAT Amritsar24 Feb 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

…ed that there is no concept of deferred revenue expenditure and once the expenditure has been incurred, the said expenditure is allowable as deduction. In the judgment of the Hon’ble Delhi High Court in the case of CIT vs. Citi Financial Consumer Finance Ltd. 335 ITR 29. The facts were that in the assessment year 2001-02, the assessee company claimed an expenditure of Rs. 3.95 crores on account of advertisement and publicity expenses as revenue expenditure. The Assessing Officer was of the view that expenditure could not be termed I.T.A. Nos.288 to 294/Asr/2015 40 expenditure relevant exclusively for the period…

THE DY. COMMISSIONER OF INCOME TAX, JAMMU vs. M/S. FIL INDUSTRIES LTD, SRINAGAR

In the result appeal of the assessee ground no 4 to 4

ITA 470/ASR/2015[2009-10]Status: DisposedITAT Amritsar24 Feb 2023AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

…ed that there is no concept of deferred revenue expenditure and once the expenditure has been incurred, the said expenditure is allowable as deduction. In the judgment of the Hon’ble Delhi High Court in the case of CIT vs. Citi Financial Consumer Finance Ltd. 335 ITR 29. The facts were that in the assessment year 2001-02, the assessee company claimed an expenditure of Rs. 3.95 crores on account of advertisement and publicity expenses as revenue expenditure. The Assessing Officer was of the view that expenditure could not be termed I.T.A. Nos.288 to 294/Asr/2015 40 expenditure relevant exclusively for the period…

M/S FIL INDUSTRIES LTD,SRINAGAR vs. THE DY COMMISSIONER OF INCOME TAX, SRINAGAR

In the result appeal of the assessee ground no 4 to 4

ITA 417/ASR/2015[2010-11]Status: DisposedITAT Amritsar24 Feb 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

…ed that there is no concept of deferred revenue expenditure and once the expenditure has been incurred, the said expenditure is allowable as deduction. In the judgment of the Hon’ble Delhi High Court in the case of CIT vs. Citi Financial Consumer Finance Ltd. 335 ITR 29. The facts were that in the assessment year 2001-02, the assessee company claimed an expenditure of Rs. 3.95 crores on account of advertisement and publicity expenses as revenue expenditure. The Assessing Officer was of the view that expenditure could not be termed I.T.A. Nos.288 to 294/Asr/2015 40 expenditure relevant exclusively for the period…

THE DY.COMMISSIONER OF INCOME-TAX, JAMMU vs. M/S FIL INDUSTRIES,, SRINAGAR

In the result appeal of the assessee ground no 4 to 4

ITA 294/ASR/2015[2008-09]Status: DisposedITAT Amritsar24 Feb 2023AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

…ed that there is no concept of deferred revenue expenditure and once the expenditure has been incurred, the said expenditure is allowable as deduction. In the judgment of the Hon’ble Delhi High Court in the case of CIT vs. Citi Financial Consumer Finance Ltd. 335 ITR 29. The facts were that in the assessment year 2001-02, the assessee company claimed an expenditure of Rs. 3.95 crores on account of advertisement and publicity expenses as revenue expenditure. The Assessing Officer was of the view that expenditure could not be termed I.T.A. Nos.288 to 294/Asr/2015 40 expenditure relevant exclusively for the period…

THE DY.COMMISSIONER OF INCOME-TAX, JAMMU vs. M/S FIL INDUSTRIES,, SRINAGAR

In the result appeal of the assessee ground no 4 to 4

ITA 293/ASR/2015[2007-08]Status: DisposedITAT Amritsar24 Feb 2023AY 2007-08

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

…ed that there is no concept of deferred revenue expenditure and once the expenditure has been incurred, the said expenditure is allowable as deduction. In the judgment of the Hon’ble Delhi High Court in the case of CIT vs. Citi Financial Consumer Finance Ltd. 335 ITR 29. The facts were that in the assessment year 2001-02, the assessee company claimed an expenditure of Rs. 3.95 crores on account of advertisement and publicity expenses as revenue expenditure. The Assessing Officer was of the view that expenditure could not be termed I.T.A. Nos.288 to 294/Asr/2015 40 expenditure relevant exclusively for the period…

THE DY.COMMISSIONER OF INCOME-TAX, JAMMU vs. M/S FIL INDUSTRIES,, SRINAGAR

In the result appeal of the assessee ground no 4 to 4

ITA 292/ASR/2015[2006-07]Status: DisposedITAT Amritsar24 Feb 2023AY 2006-07

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

…ed that there is no concept of deferred revenue expenditure and once the expenditure has been incurred, the said expenditure is allowable as deduction. In the judgment of the Hon’ble Delhi High Court in the case of CIT vs. Citi Financial Consumer Finance Ltd. 335 ITR 29. The facts were that in the assessment year 2001-02, the assessee company claimed an expenditure of Rs. 3.95 crores on account of advertisement and publicity expenses as revenue expenditure. The Assessing Officer was of the view that expenditure could not be termed I.T.A. Nos.288 to 294/Asr/2015 40 expenditure relevant exclusively for the period…

THE DY.COMMISSIONER OF INCOME-TAX, JAMMU vs. M/S FILL INDUSTRIES,, SRINAGAR

In the result appeal of the assessee ground no 4 to 4

ITA 291/ASR/2015[2004-05]Status: DisposedITAT Amritsar24 Feb 2023AY 2004-05

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

…ed that there is no concept of deferred revenue expenditure and once the expenditure has been incurred, the said expenditure is allowable as deduction. In the judgment of the Hon’ble Delhi High Court in the case of CIT vs. Citi Financial Consumer Finance Ltd. 335 ITR 29. The facts were that in the assessment year 2001-02, the assessee company claimed an expenditure of Rs. 3.95 crores on account of advertisement and publicity expenses as revenue expenditure. The Assessing Officer was of the view that expenditure could not be termed I.T.A. Nos.288 to 294/Asr/2015 40 expenditure relevant exclusively for the period…

THE DY.COMMISSIONER OF INCOME-TAX, JAMMU vs. M/S FILL INDUSTRIES,, SRINAGAR

In the result appeal of the assessee ground no 4 to 4

ITA 290/ASR/2015[2003-04]Status: DisposedITAT Amritsar24 Feb 2023AY 2003-04

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

…ed that there is no concept of deferred revenue expenditure and once the expenditure has been incurred, the said expenditure is allowable as deduction. In the judgment of the Hon’ble Delhi High Court in the case of CIT vs. Citi Financial Consumer Finance Ltd. 335 ITR 29. The facts were that in the assessment year 2001-02, the assessee company claimed an expenditure of Rs. 3.95 crores on account of advertisement and publicity expenses as revenue expenditure. The Assessing Officer was of the view that expenditure could not be termed I.T.A. Nos.288 to 294/Asr/2015 40 expenditure relevant exclusively for the period…

THE DY.COMMISSIONER OF INCOME-TAX, JAMMU vs. M/S FILL INDUSTRIES,, SRINAGAR

In the result appeal of the assessee ground no 4 to 4

ITA 289/ASR/2015[2002-03]Status: DisposedITAT Amritsar24 Feb 2023AY 2002-03

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

…ed that there is no concept of deferred revenue expenditure and once the expenditure has been incurred, the said expenditure is allowable as deduction. In the judgment of the Hon’ble Delhi High Court in the case of CIT vs. Citi Financial Consumer Finance Ltd. 335 ITR 29. The facts were that in the assessment year 2001-02, the assessee company claimed an expenditure of Rs. 3.95 crores on account of advertisement and publicity expenses as revenue expenditure. The Assessing Officer was of the view that expenditure could not be termed I.T.A. Nos.288 to 294/Asr/2015 40 expenditure relevant exclusively for the period…

M/S FIL INDUSTRIES LTD,SRINAGAR vs. THE ADDL. COMMISSIONER OF INCOME TAX, SRINAGAR

In the result appeal of the assessee ground no 4 to 4

ITA 255/ASR/2015[2008-09]Status: DisposedITAT Amritsar24 Feb 2023AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

…ed that there is no concept of deferred revenue expenditure and once the expenditure has been incurred, the said expenditure is allowable as deduction. In the judgment of the Hon’ble Delhi High Court in the case of CIT vs. Citi Financial Consumer Finance Ltd. 335 ITR 29. The facts were that in the assessment year 2001-02, the assessee company claimed an expenditure of Rs. 3.95 crores on account of advertisement and publicity expenses as revenue expenditure. The Assessing Officer was of the view that expenditure could not be termed I.T.A. Nos.288 to 294/Asr/2015 40 expenditure relevant exclusively for the period…

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE vs. M/S INFOSYS LIMITED , BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

ITA 809/BANG/2018[2013-14]Status: DisposedITAT Bangalore09 Jan 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Sri Sreenivas T. Bidari, D.R
Section 11Section 14ASection 194JSection 234BSection 40Section 80J

…if the expenditure results in an identifiable asset in the capital field. In the case of brand building, there is no identifiable asset in the capital field and hence does not constitute capital expenditure. In CIT v Citi Financial Consumer Finance Ltd(2011) 335 ITR 29, Delhi High Court observed - "the expenditure on publicity and advertisement is to be treated as revenue in nature allowable fully in the year in which it was incurred. Concededly, there is no advantage which has accrued to the assessee in the capital field. The expenditure was incurred to facilitate the assessee's trading operations. No fixed cap…

M/S INFOSYS LTD ,BANGALOR E vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

ITA 735/BANG/2018[2013-14]Status: DisposedITAT Bangalore09 Jan 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Sri Sreenivas T. Bidari, D.R
Section 11Section 14ASection 194JSection 234BSection 40Section 80J

…if the expenditure results in an identifiable asset in the capital field. In the case of brand building, there is no identifiable asset in the capital field and hence does not constitute capital expenditure. In CIT v Citi Financial Consumer Finance Ltd(2011) 335 ITR 29, Delhi High Court observed - "the expenditure on publicity and advertisement is to be treated as revenue in nature allowable fully in the year in which it was incurred. Concededly, there is no advantage which has accrued to the assessee in the capital field. The expenditure was incurred to facilitate the assessee's trading operations. No fixed cap…

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