CIT v. Mysore Sugar Co. Ltd.

46 ITR 649Supreme Court of India1962#873 most cited

What is CIT v. Mysore Sugar Co. Ltd. authority for?

When advances extended in the normal course of business operations become irrecoverable and are written off, these amounts are allowable as a business loss or revenue expenditure.

120

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2025.

Also referred to as

Mysore Sugar Co. Ltd. · 46 ITR 649 · Section 37(1) · Section 36(1)(vii) · business loss · advances written off · irrecoverable advances · revenue expenditure · allowable deduction · business expenditure

Sections most often in play

Section 37(1)Section 32Section 147Section 148Section 36(1)(vii)Section 36(2)Section 115JBSection 143(3)

Issues it is cited on

section 90aconstruction peunexplained jewellerysection 24(b)under-reporting of incomeproject completion methodsection 80cforeign tax creditroyalty incomewithholding taxdisallowance of interest expendituresection 139(4)

Judgments citing CIT v. Mysore Sugar Co. Ltd.

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4(2), DELHI, I.P.ESTATE, DELHI vs. BUREAU VERITAS CONSUMER PRODUCTS SERVICES (INDIA) PRIVATE LIMITED, LAJPAT NAGAR, NEW DELHI

In the result the appeal of the Revenue stands partly allowed for statistical purpose

ITA 3294/DEL/2023[2016-17]Status: DisposedITAT Delhi10 Nov 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

…itas Consumer Products Services (India), P. ltd. the finding of the Ld. CIT(A) that this loss is in the nature of business loss and is thus allowable. Therefore, keeping in view on the decision of the Hon’ble Supreme Court in the case of Mysore Sugar Co. Ltd. 46 ITR 649 and the decision of the Hon’ble Bombay Court in the case of Harsad J Choksi 25 taxmann.com 567 and Badri Das Daga 34 ITR 10, we are of the considered view that the said amount written off is nothing but a business loss and is thus allowable. Therefore, we do not find any infirmity in the finding of Ld. CIT(A) as far as the disallowance of advances…

ACIT, CENTRAL CIRCLE-1(1), BANGALORE vs. PADMAVATHI V., HOSPET

In the result, the appeal filed by the revenue is dismissed

ITA 2102/BANG/2024[2012]Status: DisposedITAT Bangalore18 Aug 2025

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2012-13

For Appellant: Shri T. Srinivasa, CA
Section 139(1)Section 143(2)Section 28Section 36Section 36(1)(vii)Section 44A

…, the AO had accepted the another bad debt written off by the assessee in the case of M/s. BST HK Ltd. On appeal before the Ld.CIT(A), the assessee had filed a detailed grounds of appeal and also relied on the judgment of the Hon’ble Supreme Court reported in 46 ITR 649 in the case of CIT vs. Mysore Sugar Company Limited and the other orders of this Tribunal. The assessee also contended that the expenditure incurred is a revenue expenditure since the same has been incurred purely for the business operations and therefore entitled for deduction u/s. 28 of the Act. The said plea was made by way of an alternate argu…

ACIT CIRCLE 10(1), NEW DELHI vs. IRCON INTERNATIONAL LTD, NEW DELHI

In the result, both appeals of the Revenue are dismissed as above

ITA 1108/DEL/2023[2017-18]Status: DisposedITAT Delhi18 Jul 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishra

Section 115JSection 14ASection 80I

…AO disallowed the advances of Rs.1,99,31,448/- on the reasoning that the same had never been offered as income in preceding years and the nature of advances were capital. However, the same, placing reliance on the case laws; Mysore Sugar Co. Ltd. reported in 46 ITR 649 (SC), Harsad J Choksi 25 taxmann.com567 (Bom) and Badri Das Daga 34 ITR 10, was allowed by the Ld. CIT(A) treating the same as business loss. 21. We have heard both parties and have perused the material available on record. The CIT-DR has not brought any material on the record to contradict the finding of the Ld. CIT(A). We find that the advances…

ACIT, CIRCLE-10(1), NEW DELHI vs. IRCON INTERNATIONAL LTD, NEW DELHI

In the result, both appeals of the Revenue are dismissed as above

ITA 1104/DEL/2023[2018-19]Status: DisposedITAT Delhi18 Jul 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishra

Section 115JSection 14ASection 80I

…AO disallowed the advances of Rs.1,99,31,448/- on the reasoning that the same had never been offered as income in preceding years and the nature of advances were capital. However, the same, placing reliance on the case laws; Mysore Sugar Co. Ltd. reported in 46 ITR 649 (SC), Harsad J Choksi 25 taxmann.com567 (Bom) and Badri Das Daga 34 ITR 10, was allowed by the Ld. CIT(A) treating the same as business loss. 21. We have heard both parties and have perused the material available on record. The CIT-DR has not brought any material on the record to contradict the finding of the Ld. CIT(A). We find that the advances…

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MOHALI

In the result, the appeal filed by the Revenue is dismissed

ITA 266/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh19 Feb 2025AY 2017-18

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Vineet Thakral Advocate And Shri Raman Aggarwal, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR

…ul advances is created every year which is added back before arriving at net profit. Doubtful advances are initially shown as part of income and are actually written off only when it is confirmed as bad debts. Supreme Court in the case of Mysore Sugar Co. Ltd 46 ITR 649 held that since the trade advance was made during the course of its business by the assessee, any loss on account of recoverability would automatically fall under the category of trade debt / receivable and hence is allowable as business loss. As there is no doubt that the appellant has actually extended these advances which have now become irreco…

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MOHALI

In the result, the appeal filed by the Revenue is dismissed

ITA 265/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh19 Feb 2025AY 2016-17

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Vineet Thakral Advocate And Shri Raman Aggarwal, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR

…ul advances is created every year which is added back before arriving at net profit. Doubtful advances are initially shown as part of income and are actually written off only when it is confirmed as bad debts. Supreme Court in the case of Mysore Sugar Co. Ltd 46 ITR 649 held that since the trade advance was made during the course of its business by the assessee, any loss on account of recoverability would automatically fall under the category of trade debt / receivable and hence is allowable as business loss. As there is no doubt that the appellant has actually extended these advances which have now become irreco…

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MOHALI

In the result, the appeal filed by the Revenue is dismissed

ITA 264/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh19 Feb 2025AY 2015-16

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Vineet Thakral Advocate And Shri Raman Aggarwal, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR

…ul advances is created every year which is added back before arriving at net profit. Doubtful advances are initially shown as part of income and are actually written off only when it is confirmed as bad debts. Supreme Court in the case of Mysore Sugar Co. Ltd 46 ITR 649 held that since the trade advance was made during the course of its business by the assessee, any loss on account of recoverability would automatically fall under the category of trade debt / receivable and hence is allowable as business loss. As there is no doubt that the appellant has actually extended these advances which have now become irreco…

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MOHALI

In the result, the appeal filed by the Revenue is dismissed

ITA 263/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh19 Feb 2025AY 2014-15

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Vineet Thakral Advocate And Shri Raman Aggarwal, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR

…ul advances is created every year which is added back before arriving at net profit. Doubtful advances are initially shown as part of income and are actually written off only when it is confirmed as bad debts. Supreme Court in the case of Mysore Sugar Co. Ltd 46 ITR 649 held that since the trade advance was made during the course of its business by the assessee, any loss on account of recoverability would automatically fall under the category of trade debt / receivable and hence is allowable as business loss. As there is no doubt that the appellant has actually extended these advances which have now become irreco…

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MPHALI

In the result, the appeal filed by the Revenue is dismissed

ITA 262/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh19 Feb 2025AY 2013-14

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Vineet Thakral Advocate And Shri Raman Aggarwal, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR

…ul advances is created every year which is added back before arriving at net profit. Doubtful advances are initially shown as part of income and are actually written off only when it is confirmed as bad debts. Supreme Court in the case of Mysore Sugar Co. Ltd 46 ITR 649 held that since the trade advance was made during the course of its business by the assessee, any loss on account of recoverability would automatically fall under the category of trade debt / receivable and hence is allowable as business loss. As there is no doubt that the appellant has actually extended these advances which have now become irreco…

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MPHALI

In the result, the appeal filed by the Revenue is dismissed

ITA 261/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh19 Feb 2025AY 2012-13

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Vineet Thakral Advocate And Shri Raman Aggarwal, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR

…ul advances is created every year which is added back before arriving at net profit. Doubtful advances are initially shown as part of income and are actually written off only when it is confirmed as bad debts. Supreme Court in the case of Mysore Sugar Co. Ltd 46 ITR 649 held that since the trade advance was made during the course of its business by the assessee, any loss on account of recoverability would automatically fall under the category of trade debt / receivable and hence is allowable as business loss. As there is no doubt that the appellant has actually extended these advances which have now become irreco…

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MPHALI

In the result, the appeal filed by the Revenue is dismissed

ITA 260/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh19 Feb 2025AY 2011-12

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Vineet Thakral Advocate And Shri Raman Aggarwal, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR

…ul advances is created every year which is added back before arriving at net profit. Doubtful advances are initially shown as part of income and are actually written off only when it is confirmed as bad debts. Supreme Court in the case of Mysore Sugar Co. Ltd 46 ITR 649 held that since the trade advance was made during the course of its business by the assessee, any loss on account of recoverability would automatically fall under the category of trade debt / receivable and hence is allowable as business loss. As there is no doubt that the appellant has actually extended these advances which have now become irreco…

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MPHALI

In the result, the appeal filed by the Revenue is dismissed

ITA 259/CHANDI/2023[2010-11]Status: DisposedITAT Chandigarh19 Feb 2025AY 2010-11

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Vineet Thakral Advocate And Shri Raman Aggarwal, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR

…ul advances is created every year which is added back before arriving at net profit. Doubtful advances are initially shown as part of income and are actually written off only when it is confirmed as bad debts. Supreme Court in the case of Mysore Sugar Co. Ltd 46 ITR 649 held that since the trade advance was made during the course of its business by the assessee, any loss on account of recoverability would automatically fall under the category of trade debt / receivable and hence is allowable as business loss. As there is no doubt that the appellant has actually extended these advances which have now become irreco…

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MOHALI

In the result, the appeal filed by the Revenue is dismissed

ITA 258/CHANDI/2023[2009-10]Status: DisposedITAT Chandigarh19 Feb 2025AY 2009-10

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Vineet Thakral Advocate And Shri Raman Aggarwal, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR

…ul advances is created every year which is added back before arriving at net profit. Doubtful advances are initially shown as part of income and are actually written off only when it is confirmed as bad debts. Supreme Court in the case of Mysore Sugar Co. Ltd 46 ITR 649 held that since the trade advance was made during the course of its business by the assessee, any loss on account of recoverability would automatically fall under the category of trade debt / receivable and hence is allowable as business loss. As there is no doubt that the appellant has actually extended these advances which have now become irreco…

TITAN COMPANY LIMITED,HOSUR vs. ASSISTANT COMMISSIONER OF INCOME TAX - LTU 2 (IC), CHENNAI

In the result the appeal raised by the assessee is partly allowed

ITA 1742/CHNY/2024[2011- 12]Status: DisposedITAT Chennai04 Dec 2024

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1742/Chny/2024 निर्धारण वर्ा /Assessment Years: 2011-12 Titan Company Limited, Assistant Commissioner Of No.3, Sipcot Industrial Complex, Income Tax, Hosur, Krishnagiri, Ltu-2, Tamil Nadu-635126 Chennai [Pan: Aaact5131A] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Abhay Kumar, C.A अपीलार्थी की ओर से/ Assessee By : Ms.Komali Krishna, Cit प्रत्यर्थी की ओर से /Revenue By सुनवाई की तारीख/Date Of Hearing : 10.09.2024 घोषणा की तारीख /Date Of Pronouncement : 04.12.2024

For Appellant: Ms.Komali Krishna, CIT
Section 147Section 250Section 80Section 80C(2)(a)Section 80I

…ishable since the assessee's subsidiary was executing contracts on behalf of the assessee. The assessee settled the claim of subsidiaries with the bankers. The same is not the case here. The decision of Hon'ble Supreme Court in CIT V/s Mysore Sugars Co. Ltd. (46 ITR 649) is a case of business advances. Therefore, in our considered opinion, no further deduction could be allowed to assessee as rightly held by lower authorities. The corresponding grounds stand dismissed….” 7.0 We have however noted that the assessee has tried to distinguish the above decision adjudicated by the Hon’ble Coordinate Bench of this Tribu…

THE LOUIS BERGER GROUP INC,GUGAON vs. ASSISTANT COMMISSIONER OF INCOMNE TAX, INTERNATIONAL TAXATION, GURGAON

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

ITA 2630/DEL/2023[2020-21]Status: DisposedITAT Delhi15 Oct 2024AY 2020-21

Bench: Shri Saktijit Dey, Hon’Ble & Shri M. Balaganeshthe Louis Berger Group Inc, Vs. Acit, Plot No. 3, Surinder Jakhir Dcit/Acit, International Bhawan, Sector-32, Gurgaon Taxation, Gurgaon (Appellant) (Respondent) Pan:Aaacl4067F

For Appellant: Shri Deepak Chopra, AdvFor Respondent: Shri Vijay B. Vazanta, CIT DR
Section 36(1)(vii)Section 36(2)

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”: NEW DELHI BEFORE SHRI SAKTIJIT DEY, HON’BLE VICE PRESIDENT AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER The Louis Berger Group Inc, Vs. ACIT, Plot No. 3, Surinder Jakhir DCIT/ACIT, International Bhawan, Sector-32, Gurgaon Taxation, Gurgaon (Appellant) (Respondent) PAN:AAACL4067F SA No. 385/Del/2023 (In ITA No. 2630/Del/2023) (Assessment Year: 2020-21) The Louis Berger Group Inc, Vs. ACIT, Plot No. 3, Surinder Jakhir DCIT/ACIT, International Bhawan, Sector-32, Gurgaon Taxation, Gurgaon (Appellant) (Respondent) PAN:AAACL4067F Assessee by : Shri Deepak Chopra, Adv Shri A…

ANJAPPAN RANGASMY,CHENNAI vs. DCIT,CENTRAL CIRCLE-1(3), CHENNAI

Appeals stand allowed in terms of our above order

ITA 321/CHNY/2024[2018-19]Status: DisposedITAT Chennai06 Aug 2024AY 2018-19

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकर अपील सं./ Ita No.301/Chny/2024 (िनधा(रणवष( / Assessment Year: 2013-14) & 2. आयकर अपील सं./ Ita No.302 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2014-15) & 3. आयकर अपील सं./ Ita No.303/Chny/2024 (िनधा(रणवष( / Assessment Year: 2015-16) & 4. आयकर अपील सं./ Ita No.304 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2016-17) & 5. आयकर अपील सं./ Ita No.305/Chny/2024 (िनधा(रणवष( / Assessment Year: 2017-18) & 6. आयकर अपील सं./ Ita No.306 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2018-19) & 7. आयकर अपील सं./ Ita No.307 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2019-20) & 8. आयकर अपील सं./ Ita No.316/Chny/2024 (िनधा(रणवष( / Assessment Year: 2013-14) & 9. आयकर अपील सं./ Ita No.317/Chny/2024 (िनधा(रणवष( / Assessment Year: 2014-15)

For Appellant: Shri R.Venkata Raman (CA) - Ld. ARFor Respondent: Shri Nilay Baran Som (CIT) - Ld. Sr.DR
Section 132Section 153ASection 24Section 54Section 80CSection 90A

…ated 09-09-2014. The assessee claimed the same on the ground that the same were trade advances and non- recoverable and hence, allowable as business deduction. Reliance was placed on the decision of Hon’ble Supreme Court in the case of Mysore Sugars Co. Ltd. (46 ITR 649). The Ld. CIT(A) upheld the disallowance on the ground that the assessee had intention of venturing into the hotel business and made investment out of borrowing from M/s Sundaram Finance. The payment had no nexus with the business of the assessee. This was a capital investment and such loss would be capital loss. Aggrieved, the assessee is in furt…

ANJAPPAN RANGASAMY,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(3), CHENNAI

Appeals stand allowed in terms of our above order

ITA 320/CHNY/2024[2017-18]Status: DisposedITAT Chennai06 Aug 2024AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकर अपील सं./ Ita No.301/Chny/2024 (िनधा(रणवष( / Assessment Year: 2013-14) & 2. आयकर अपील सं./ Ita No.302 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2014-15) & 3. आयकर अपील सं./ Ita No.303/Chny/2024 (िनधा(रणवष( / Assessment Year: 2015-16) & 4. आयकर अपील सं./ Ita No.304 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2016-17) & 5. आयकर अपील सं./ Ita No.305/Chny/2024 (िनधा(रणवष( / Assessment Year: 2017-18) & 6. आयकर अपील सं./ Ita No.306 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2018-19) & 7. आयकर अपील सं./ Ita No.307 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2019-20) & 8. आयकर अपील सं./ Ita No.316/Chny/2024 (िनधा(रणवष( / Assessment Year: 2013-14) & 9. आयकर अपील सं./ Ita No.317/Chny/2024 (िनधा(रणवष( / Assessment Year: 2014-15)

For Appellant: Shri R.Venkata Raman (CA) - Ld. ARFor Respondent: Shri Nilay Baran Som (CIT) - Ld. Sr.DR
Section 132Section 153ASection 24Section 54Section 80CSection 90A

…ated 09-09-2014. The assessee claimed the same on the ground that the same were trade advances and non- recoverable and hence, allowable as business deduction. Reliance was placed on the decision of Hon’ble Supreme Court in the case of Mysore Sugars Co. Ltd. (46 ITR 649). The Ld. CIT(A) upheld the disallowance on the ground that the assessee had intention of venturing into the hotel business and made investment out of borrowing from M/s Sundaram Finance. The payment had no nexus with the business of the assessee. This was a capital investment and such loss would be capital loss. Aggrieved, the assessee is in furt…

ANJAPPAN RANGASAMY,CHENNAI vs. DCIT,CENTRL CIRCLE-1(3), CHENNAI

Appeals stand allowed in terms of our above order

ITA 319/CHNY/2024[2016-17]Status: DisposedITAT Chennai06 Aug 2024AY 2016-17

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकर अपील सं./ Ita No.301/Chny/2024 (िनधा(रणवष( / Assessment Year: 2013-14) & 2. आयकर अपील सं./ Ita No.302 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2014-15) & 3. आयकर अपील सं./ Ita No.303/Chny/2024 (िनधा(रणवष( / Assessment Year: 2015-16) & 4. आयकर अपील सं./ Ita No.304 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2016-17) & 5. आयकर अपील सं./ Ita No.305/Chny/2024 (िनधा(रणवष( / Assessment Year: 2017-18) & 6. आयकर अपील सं./ Ita No.306 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2018-19) & 7. आयकर अपील सं./ Ita No.307 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2019-20) & 8. आयकर अपील सं./ Ita No.316/Chny/2024 (िनधा(रणवष( / Assessment Year: 2013-14) & 9. आयकर अपील सं./ Ita No.317/Chny/2024 (िनधा(रणवष( / Assessment Year: 2014-15)

For Appellant: Shri R.Venkata Raman (CA) - Ld. ARFor Respondent: Shri Nilay Baran Som (CIT) - Ld. Sr.DR
Section 132Section 153ASection 24Section 54Section 80CSection 90A

…ated 09-09-2014. The assessee claimed the same on the ground that the same were trade advances and non- recoverable and hence, allowable as business deduction. Reliance was placed on the decision of Hon’ble Supreme Court in the case of Mysore Sugars Co. Ltd. (46 ITR 649). The Ld. CIT(A) upheld the disallowance on the ground that the assessee had intention of venturing into the hotel business and made investment out of borrowing from M/s Sundaram Finance. The payment had no nexus with the business of the assessee. This was a capital investment and such loss would be capital loss. Aggrieved, the assessee is in furt…

ANJAPPAN RANGASAMY,CHENNAI vs. DCIT,CENTRAL CIRCLE-1(3), CHENNAI

Appeals stand allowed in terms of our above order

ITA 318/CHNY/2024[2015-16]Status: DisposedITAT Chennai06 Aug 2024AY 2015-16

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकर अपील सं./ Ita No.301/Chny/2024 (िनधा(रणवष( / Assessment Year: 2013-14) & 2. आयकर अपील सं./ Ita No.302 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2014-15) & 3. आयकर अपील सं./ Ita No.303/Chny/2024 (िनधा(रणवष( / Assessment Year: 2015-16) & 4. आयकर अपील सं./ Ita No.304 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2016-17) & 5. आयकर अपील सं./ Ita No.305/Chny/2024 (िनधा(रणवष( / Assessment Year: 2017-18) & 6. आयकर अपील सं./ Ita No.306 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2018-19) & 7. आयकर अपील सं./ Ita No.307 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2019-20) & 8. आयकर अपील सं./ Ita No.316/Chny/2024 (िनधा(रणवष( / Assessment Year: 2013-14) & 9. आयकर अपील सं./ Ita No.317/Chny/2024 (िनधा(रणवष( / Assessment Year: 2014-15)

For Appellant: Shri R.Venkata Raman (CA) - Ld. ARFor Respondent: Shri Nilay Baran Som (CIT) - Ld. Sr.DR
Section 132Section 153ASection 24Section 54Section 80CSection 90A

…ated 09-09-2014. The assessee claimed the same on the ground that the same were trade advances and non- recoverable and hence, allowable as business deduction. Reliance was placed on the decision of Hon’ble Supreme Court in the case of Mysore Sugars Co. Ltd. (46 ITR 649). The Ld. CIT(A) upheld the disallowance on the ground that the assessee had intention of venturing into the hotel business and made investment out of borrowing from M/s Sundaram Finance. The payment had no nexus with the business of the assessee. This was a capital investment and such loss would be capital loss. Aggrieved, the assessee is in furt…

ANJAPPAN RANGASAMY,CHENNAI vs. DCITCENTRAL CIRCLE-1(3), CHENNAI

Appeals stand allowed in terms of our above order

ITA 317/CHNY/2024[2014-15]Status: DisposedITAT Chennai06 Aug 2024AY 2014-15

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकर अपील सं./ Ita No.301/Chny/2024 (िनधा(रणवष( / Assessment Year: 2013-14) & 2. आयकर अपील सं./ Ita No.302 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2014-15) & 3. आयकर अपील सं./ Ita No.303/Chny/2024 (िनधा(रणवष( / Assessment Year: 2015-16) & 4. आयकर अपील सं./ Ita No.304 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2016-17) & 5. आयकर अपील सं./ Ita No.305/Chny/2024 (िनधा(रणवष( / Assessment Year: 2017-18) & 6. आयकर अपील सं./ Ita No.306 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2018-19) & 7. आयकर अपील सं./ Ita No.307 /Chny/2024 (िनधा(रणवष( / Assessment Year: 2019-20) & 8. आयकर अपील सं./ Ita No.316/Chny/2024 (िनधा(रणवष( / Assessment Year: 2013-14) & 9. आयकर अपील सं./ Ita No.317/Chny/2024 (िनधा(रणवष( / Assessment Year: 2014-15)

For Appellant: Shri R.Venkata Raman (CA) - Ld. ARFor Respondent: Shri Nilay Baran Som (CIT) - Ld. Sr.DR
Section 132Section 153ASection 24Section 54Section 80CSection 90A

…ated 09-09-2014. The assessee claimed the same on the ground that the same were trade advances and non- recoverable and hence, allowable as business deduction. Reliance was placed on the decision of Hon’ble Supreme Court in the case of Mysore Sugars Co. Ltd. (46 ITR 649). The Ld. CIT(A) upheld the disallowance on the ground that the assessee had intention of venturing into the hotel business and made investment out of borrowing from M/s Sundaram Finance. The payment had no nexus with the business of the assessee. This was a capital investment and such loss would be capital loss. Aggrieved, the assessee is in furt…

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CIT v. Mysore Sugar Co. Ltd. (46 ITR 649) — Cited in 120 Judgments | BharatTax