CIT v. Madras Refineries Ltd.

266 ITR 170High Court2004#1206 most cited

What is CIT v. Madras Refineries Ltd. authority for?

Expenses incurred for community development, even if not directly linked to business operations, can be considered allowable business expenditure if they foster goodwill and are part of evolving business practices.

94

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2013 to 2026.

Also referred to as

CIT v. Madras Refineries Ltd. · section 37(1) · business expenditure · community development expenses · goodwill · corporate social responsibility · allowable expenses · evolving concept of business

Also reported as

138 Taxmann 261

Sections most often in play

Section 14ASection 37(1)Section 115JBSection 135Section 143(3)Section 154Section 8DSection 143(1)(a)

Issues it is cited on

section 35acsection 36(1)(viia)(c)section 40(a)(1)section 80ia(1)section 80hhesection 35absection 248section 135section 35acsr expendituresection 9(1)(vii)(b)substance over form

Judgments citing CIT v. Madras Refineries Ltd.

Deputy Commissioner of Income Tax, Chennai vs. M/S. Chemplast Sanmar Limited, Chennai

In the result, the appeal filed by the Revenue is partly-allowed for statistical purposes

ITA 2627/CHNY/2025[2017-18]Status: DisposedITAT Chennai06 Feb 2026AY 2017-18

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 2627/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of Chemplast Sanmar Limited, Income Tax, Vs. 9, Cathedral Road, Non-Corporate Circle 8, Chennai - 600 086. Chennai Pan: Aaacc 3000F (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. Gouthami Manivasagam, Addl.Cit ""यथ" क" ओर से/Respondent By : Shri R. Vijayaraghavan, Advocate सुनवाई क" तारीख/Date Of Hearing : 03.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 06.02.2026

For Appellant: Ms. Gouthami ManivasagamFor Respondent: Shri R. Vijayaraghavan, Advocate
Section 115JSection 143(3)Section 14ASection 40A(7)Section 40A(7)(b)Section 40A(9)Section 43B

…re incurred to earn exempt income, no disallowance u/s.14A can be made. The CIT(A) also directed the AO to allow addition made on account of CSR expenses following the decision of the Hon’ble High Court of Madras in the case of CIT vs. Madras Refineries Ltd., 266 ITR 170. Lastly, the CIT(A) directed the AO not to add the provision for gratuity for the purpose of book profit u/s.115JB of the Act following the Tribunal’s order in assessee’s own case for assessment years 2008-09 to 2014-15. Similarly, the CIT(A) deleted the addition made u/s.14A of the Act to the book profits u/s.115JB of the Act. :- 4 -: 5. Being a…

Andhra Pradesh Power Generation Corporation Limited, Vijayawada vs. Deputy Commissioner of Income Tax, Circle 1(1), Vijayawada

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 197/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam20 Aug 2025AY 2020-21

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

Section 143(1)(a)Section 143(3)Section 14ASection 37(1)Section 40

…re the business is situated. On this issue, he relied on the decision of the 22 I.T.A.No.191, 192, 193, 194, 195, 196 & 197/Viz/2024 AP Power Generation Corporation Ltd Hon’ble Madras High Court in the case of CIT vs. Madras Refineries Ltd reported in [2000] 266 ITR 170 (Madras). 37. Per contra, the Ld. DR submitted that the Explantion-2 to section 37(1) of the Act was introduced from 01/04/2015 and the expenditure incurred in order to comply with the CSR and hence cannot be allowed as expenditure. He therefore pleaded that the orders of the Ld. Revenue Authorities be upheld. 38. We have heard both the sides…

Andhra Pradesh Power Generation Corporation Limited, Vijayawada vs. Deputy Commissioner of Income Tax, Circle1(1), Vijayawada

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 196/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam20 Aug 2025AY 2018-19

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 143(1)(a)Section 143(3)Section 14ASection 37(1)Section 40

…re the business is situated. On this issue, he relied on the decision of the 22 I.T.A.No.191, 192, 193, 194, 195, 196 & 197/Viz/2024 AP Power Generation Corporation Ltd Hon’ble Madras High Court in the case of CIT vs. Madras Refineries Ltd reported in [2000] 266 ITR 170 (Madras). 37. Per contra, the Ld. DR submitted that the Explantion-2 to section 37(1) of the Act was introduced from 01/04/2015 and the expenditure incurred in order to comply with the CSR and hence cannot be allowed as expenditure. He therefore pleaded that the orders of the Ld. Revenue Authorities be upheld. 38. We have heard both the sides…

Andhra Pradesh Power Generation Corporation Limited, Vijayawada vs. Deputy Commissioner of Income Tax, Circle-1(1), Vijayawada

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 195/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam20 Aug 2025AY 2017-18

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

Section 143(1)(a)Section 143(3)Section 14ASection 37(1)Section 40

…re the business is situated. On this issue, he relied on the decision of the 22 I.T.A.No.191, 192, 193, 194, 195, 196 & 197/Viz/2024 AP Power Generation Corporation Ltd Hon’ble Madras High Court in the case of CIT vs. Madras Refineries Ltd reported in [2000] 266 ITR 170 (Madras). 37. Per contra, the Ld. DR submitted that the Explantion-2 to section 37(1) of the Act was introduced from 01/04/2015 and the expenditure incurred in order to comply with the CSR and hence cannot be allowed as expenditure. He therefore pleaded that the orders of the Ld. Revenue Authorities be upheld. 38. We have heard both the sides…

Andhra Pradesh Power Generation Corporation Limited, Vijayawada vs. Deputy Commissioner of Income Tax, Circle-1(1), Vijayawada

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 193/VIZ/2024[2013-14]Status: DisposedITAT Visakhapatnam20 Aug 2025AY 2013-14

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

Section 143(1)(a)Section 143(3)Section 14ASection 37(1)Section 40

…re the business is situated. On this issue, he relied on the decision of the 22 I.T.A.No.191, 192, 193, 194, 195, 196 & 197/Viz/2024 AP Power Generation Corporation Ltd Hon’ble Madras High Court in the case of CIT vs. Madras Refineries Ltd reported in [2000] 266 ITR 170 (Madras). 37. Per contra, the Ld. DR submitted that the Explantion-2 to section 37(1) of the Act was introduced from 01/04/2015 and the expenditure incurred in order to comply with the CSR and hence cannot be allowed as expenditure. He therefore pleaded that the orders of the Ld. Revenue Authorities be upheld. 38. We have heard both the sides…

Andhra Pradesh Power Generation Corporation Limited, Vijayawada vs. Deputy Commissioner of Income Tax, Circle-1(1), Vijayawada

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 192/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam20 Aug 2025AY 2015-16

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

Section 143(1)(a)Section 143(3)Section 14ASection 37(1)Section 40

…re the business is situated. On this issue, he relied on the decision of the 22 I.T.A.No.191, 192, 193, 194, 195, 196 & 197/Viz/2024 AP Power Generation Corporation Ltd Hon’ble Madras High Court in the case of CIT vs. Madras Refineries Ltd reported in [2000] 266 ITR 170 (Madras). 37. Per contra, the Ld. DR submitted that the Explantion-2 to section 37(1) of the Act was introduced from 01/04/2015 and the expenditure incurred in order to comply with the CSR and hence cannot be allowed as expenditure. He therefore pleaded that the orders of the Ld. Revenue Authorities be upheld. 38. We have heard both the sides…

Andhra Pradesh Power Generation Corporation Limited, Vijayawada vs. Deputy Commissioner of Income Tax, Circle 1(1), Vijayawada

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 191/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam20 Aug 2025AY 2016-17

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

Section 143(1)(a)Section 143(3)Section 14ASection 37(1)Section 40

…re the business is situated. On this issue, he relied on the decision of the 22 I.T.A.No.191, 192, 193, 194, 195, 196 & 197/Viz/2024 AP Power Generation Corporation Ltd Hon’ble Madras High Court in the case of CIT vs. Madras Refineries Ltd reported in [2000] 266 ITR 170 (Madras). 37. Per contra, the Ld. DR submitted that the Explantion-2 to section 37(1) of the Act was introduced from 01/04/2015 and the expenditure incurred in order to comply with the CSR and hence cannot be allowed as expenditure. He therefore pleaded that the orders of the Ld. Revenue Authorities be upheld. 38. We have heard both the sides…

Hudco Ltd. (Housing & Urban Development Corporation Ltd), New Delhi vs. Addl. CIT, Special Range-4, New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 7218/DEL/2018[2015-16]Status: DisposedITAT Delhi31 Jul 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

…e expenditure should be determined based on the fact whether it had resulted in overall welfare / benefit of the society at large. Reliance in this regard is placed on the decision of Hon'ble Madras High Court in the case of CIT Vs. Madras Refineries reported 266 ITR 170 (Mad) wherein, it was held that even a remote nexus to a business of the assessee is allowable revenue expenditure. The relevant observation is reproduced herein below:- "5. The concept of business is not static. It has evolved over a period of time to include within its fold the concrete expression of care and concern for the society at large a…

Addl. CIT, Special Range-4, New Delhi vs. Hudco Ltd. (Housing & Urban Development Corporation Ltd), New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 6829/DEL/2018[2015-16]Status: DisposedITAT Delhi31 Jul 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

…e expenditure should be determined based on the fact whether it had resulted in overall welfare / benefit of the society at large. Reliance in this regard is placed on the decision of Hon'ble Madras High Court in the case of CIT Vs. Madras Refineries reported 266 ITR 170 (Mad) wherein, it was held that even a remote nexus to a business of the assessee is allowable revenue expenditure. The relevant observation is reproduced herein below:- "5. The concept of business is not static. It has evolved over a period of time to include within its fold the concrete expression of care and concern for the society at large a…

Addl. CIT, Special Range- 4, New Delhi vs. Hudco Ltd., New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 2063/DEL/2018[2014-15]Status: DisposedITAT Delhi31 Jul 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

…e expenditure should be determined based on the fact whether it had resulted in overall welfare / benefit of the society at large. Reliance in this regard is placed on the decision of Hon'ble Madras High Court in the case of CIT Vs. Madras Refineries reported 266 ITR 170 (Mad) wherein, it was held that even a remote nexus to a business of the assessee is allowable revenue expenditure. The relevant observation is reproduced herein below:- "5. The concept of business is not static. It has evolved over a period of time to include within its fold the concrete expression of care and concern for the society at large a…

Housing & Urban Development Corporation Ltd, New Delhi vs. Addl. CIT, Range-4, New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 1954/DEL/2018[2014-15]Status: DisposedITAT Delhi31 Jul 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

…e expenditure should be determined based on the fact whether it had resulted in overall welfare / benefit of the society at large. Reliance in this regard is placed on the decision of Hon'ble Madras High Court in the case of CIT Vs. Madras Refineries reported 266 ITR 170 (Mad) wherein, it was held that even a remote nexus to a business of the assessee is allowable revenue expenditure. The relevant observation is reproduced herein below:- "5. The concept of business is not static. It has evolved over a period of time to include within its fold the concrete expression of care and concern for the society at large a…

Addl. CIT, New Delhi vs. M/S. Hudco Ltd., New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 3704/DEL/2017[2012-13]Status: DisposedITAT Delhi31 Jul 2025AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

…e expenditure should be determined based on the fact whether it had resulted in overall welfare / benefit of the society at large. Reliance in this regard is placed on the decision of Hon'ble Madras High Court in the case of CIT Vs. Madras Refineries reported 266 ITR 170 (Mad) wherein, it was held that even a remote nexus to a business of the assessee is allowable revenue expenditure. The relevant observation is reproduced herein below:- "5. The concept of business is not static. It has evolved over a period of time to include within its fold the concrete expression of care and concern for the society at large a…

M/S. Housing & Urban Development Corporation Ltd., New Delhi vs. DCIT, New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 3305/DEL/2017[2012-13]Status: DisposedITAT Delhi31 Jul 2025AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

…e expenditure should be determined based on the fact whether it had resulted in overall welfare / benefit of the society at large. Reliance in this regard is placed on the decision of Hon'ble Madras High Court in the case of CIT Vs. Madras Refineries reported 266 ITR 170 (Mad) wherein, it was held that even a remote nexus to a business of the assessee is allowable revenue expenditure. The relevant observation is reproduced herein below:- "5. The concept of business is not static. It has evolved over a period of time to include within its fold the concrete expression of care and concern for the society at large a…

DCIT, New Delhi vs. M/S Hudco Ltd., New Delhi

In the result, the appeal of the revenue in ITA No

ITA 3904/DEL/2015[2010-11]Status: DisposedITAT Delhi04 Nov 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Waseem Arshad, CIT DR &
Section 143(3)

…servation made by the ld CIT(A) qua this ground. Hence the same is hereby ignored as it is not germane to the issue in dispute. We find that the ld AR relied on the decision of the Hon’ble Madras High Court in the case of CIT Vs. Madras Refineries reported in 266 ITR 170 (Mad) wherein, it was held that even a remote nexus to a business of the assessee is allowable revenue expenditure. The relevant observation is reproduced herein below:- “5. The concept of business is not static. It has evolved over a period of time to include within its fold the concrete expression of care and concern for the society ITA No. 32…

M/S. Housing & Urban Development Corporation Ltd. (Hudco), New Delhi vs. Addl. CIT, New Delhi

In the result, the appeal of the revenue in ITA No

ITA 3261/DEL/2015[2010-11]Status: DisposedITAT Delhi04 Nov 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Waseem Arshad, CIT DR &
Section 143(3)

…servation made by the ld CIT(A) qua this ground. Hence the same is hereby ignored as it is not germane to the issue in dispute. We find that the ld AR relied on the decision of the Hon’ble Madras High Court in the case of CIT Vs. Madras Refineries reported in 266 ITR 170 (Mad) wherein, it was held that even a remote nexus to a business of the assessee is allowable revenue expenditure. The relevant observation is reproduced herein below:- “5. The concept of business is not static. It has evolved over a period of time to include within its fold the concrete expression of care and concern for the society ITA No. 32…

DCIT, CC -1(4), Mumbai vs. M/S. Hindalco Industries Ltd., Mumbai

Accordingly, there is no substance raised by the department and the same is dismissed

ITA 619/KOL/2007[2003-04]Status: DisposedITAT Mumbai04 Jul 2024AY 2003-04
Section 115JSection 143(3)Section 80Section 80I

…AO has disallowed the expenses treating it as a donation in the nature being not credited with the business of the assessee. This issue stands covered by the Hon'ble Madras High Court in the case of Commissioner of Income Tax v. Madras Refineries Ltd. (2004) 266 ITR 170 (Mad) wherein under similar circumstances, the assessee therein had incurred community development expenses of the same nature, and the said expenses were finally held to be non-philanthropic in nature, incurred wholly for the purpose of business. The relevant extract of the judgement is reproduced hereinbelow: 5. The concept of business is not s…

M/S. Hindalco Industries Ltd.(Earlier Known As Indian Aluminium Company Ltd), Mumbai vs. DCIT, CC -1(4) (Earlier Deputy Commissioner of Income Tax Circle-8, Kolkatta), Mumbai

ITA 612/KOL/2007[2003-04]Status: DisposedITAT Mumbai04 Jul 2024AY 2003-04
Section 115JSection 143(3)Section 80Section 80I

…AO has disallowed the expenses treating it as a donation in the nature being not credited with the business of the assessee. This issue stands covered by the Hon'ble Madras High Court in the case of Commissioner of Income Tax v. Madras Refineries Ltd. (2004) 266 ITR 170 (Mad) wherein under similar circumstances, the assessee therein had incurred community development expenses of the same nature, and the said expenses were finally held to be non-philanthropic in nature, incurred wholly for the purpose of business. The relevant extract of the judgement is reproduced hereinbelow: 5. The concept of business is not…

Rane Engine Valve Ltd, Chennai vs. DCIT Corporate Circle-5(1), Chennai

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

ITA 885/CHNY/2020[2015-16]Status: DisposedITAT Chennai03 Jul 2024AY 2015-16

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri G. Suresh, JCIT
Section 143(3)

…आयकर अपीलीय अिधकरण, ‘डी’ "यायपीठ,चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI "ी महावीर "सह, उपा"य" एवं"ी अिमताभ शु"ला, लेखा सद"य के सम" BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENTAND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.: 1497, 1498/CHNY/2017, 1477, 2815/CHNY/2018 & 885/CHNY/2020 िनधा"रण वष"/Assessment Years:2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 Rane Engine Valve Limited, The Deputy Commissioner of “Maithri”, No.132, Vs. Income Tax, Cathedral Road, Corporate Circle 5(1), Chennai – 600 086. Chennai. PAN: AAACT 1279M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क"…

Rane Engine Valve Limited, Chennai vs. DCIT Corporate Circle 5(1), Chennai

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

ITA 2815/CHNY/2018[2014-15]Status: DisposedITAT Chennai03 Jul 2024AY 2014-15

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri G. Suresh, JCIT
Section 143(3)

…आयकर अपीलीय अिधकरण, ‘डी’ "यायपीठ,चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI "ी महावीर "सह, उपा"य" एवं"ी अिमताभ शु"ला, लेखा सद"य के सम" BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENTAND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.: 1497, 1498/CHNY/2017, 1477, 2815/CHNY/2018 & 885/CHNY/2020 िनधा"रण वष"/Assessment Years:2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 Rane Engine Valve Limited, The Deputy Commissioner of “Maithri”, No.132, Vs. Income Tax, Cathedral Road, Corporate Circle 5(1), Chennai – 600 086. Chennai. PAN: AAACT 1279M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क"…

Rane Engine Valve Limited, Chennai vs. DCIT Corporate Circle 5 (1), Chennai

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

ITA 1477/CHNY/2018[2013-14]Status: DisposedITAT Chennai03 Jul 2024AY 2013-14

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri G. Suresh, JCIT
Section 143(3)

…आयकर अपीलीय अिधकरण, ‘डी’ "यायपीठ,चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI "ी महावीर "सह, उपा"य" एवं"ी अिमताभ शु"ला, लेखा सद"य के सम" BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENTAND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.: 1497, 1498/CHNY/2017, 1477, 2815/CHNY/2018 & 885/CHNY/2020 िनधा"रण वष"/Assessment Years:2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 Rane Engine Valve Limited, The Deputy Commissioner of “Maithri”, No.132, Vs. Income Tax, Cathedral Road, Corporate Circle 5(1), Chennai – 600 086. Chennai. PAN: AAACT 1279M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क"…