Eastern Investments Ltd. v. CIT

38 ITR 601Supreme Court of India1960#222 most cited

What is Eastern Investments Ltd. v. CIT authority for?

Expenditure must be commercially expedient for carrying on the business, and it is not for revenue authorities to dictate how an assessee should conduct its business. The court will not question the business expediency of a transaction, even if a third party also benefits.

346

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2006 to 2026.

Also referred to as

Eastern Investments Ltd. v. CIT · 38 ITR 601 · commercial expediency · business expediency · related party transaction · enduring benefit · business expenditure · prudent businessman · disallowance of interest expenditure

Sections most often in play

Section 143(3)Section 147Section 148Section 14ASection 37Section 234BSection 40A(2)(b)Section 37(1)

Issues it is cited on

interest on interestaccumulated profitssection 40a(2)(b)commercial expediencyrelated party transactionbusiness expediencysection 194jenduring benefitsection 40a(2)section 14a(2)disallowance of interest expendituresection 36(1)(vii)

Judgments citing Eastern Investments Ltd. v. CIT

M/S. Thiruvalluvar Textiles Pvt. Ltd., Rasipuram vs. ACIT, Central Circle-1(1), Chennai

In the result, the appeal of the assessee is allowed for A

ITA 1737/CHNY/2025[2017-18]Status: DisposedITAT Chennai04 Nov 2025AY 2017-18

Bench: Shri George George K & Shri S.R.Raghunatha

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Shri. Shiva Srinivas, CIT
Section 11

…nded, not necessity and with a view to direct and immediate benefit, but voluntarily and on the grounds of commercial expediency and in order to indirectly facilitate the carrying on the business as held in the case of CIT vs Chandulal Keshavlal & Co (1960) 38 ITR 601. 21. In the case of ACIT vs T Bhimjyani Realty P Ltd ITAT Mumbai dated 16/01/2025 in ITANo 4901/Mum/2024 held that “if advance /investment made by the assessee to its sister concern interest for the purpose of commercial expediency, no disallowance of interest can be made as the expenditure expanded for the purpose of business u/s 36 and 37 of I…

M/S. Thiruvalluvar Textiles Pvt. Ltd., Rasipuram vs. ACIT, Central Circle-1(1), Chennai

In the result, the appeal of the assessee is allowed for A

ITA 1736/CHNY/2025[2016-17]Status: DisposedITAT Chennai04 Nov 2025AY 2016-17

Bench: Shri George George K & Shri S.R.Raghunatha

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Shri. Shiva Srinivas, CIT
Section 11

…nded, not necessity and with a view to direct and immediate benefit, but voluntarily and on the grounds of commercial expediency and in order to indirectly facilitate the carrying on the business as held in the case of CIT vs Chandulal Keshavlal & Co (1960) 38 ITR 601. 21. In the case of ACIT vs T Bhimjyani Realty P Ltd ITAT Mumbai dated 16/01/2025 in ITANo 4901/Mum/2024 held that “if advance /investment made by the assessee to its sister concern interest for the purpose of commercial expediency, no disallowance of interest can be made as the expenditure expanded for the purpose of business u/s 36 and 37 of I…

M/S.Thiruvalluvar Textiles Pvt. Ltd., Rasipuram vs. ACIT, Central Circle-1(1), Chennai

In the result, the appeal of the assessee is allowed for A

ITA 1735/CHNY/2025[2014-15]Status: DisposedITAT Chennai04 Nov 2025AY 2014-15

Bench: Shri George George K & Shri S.R.Raghunatha

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Shri. Shiva Srinivas, CIT
Section 11

…nded, not necessity and with a view to direct and immediate benefit, but voluntarily and on the grounds of commercial expediency and in order to indirectly facilitate the carrying on the business as held in the case of CIT vs Chandulal Keshavlal & Co (1960) 38 ITR 601. 21. In the case of ACIT vs T Bhimjyani Realty P Ltd ITAT Mumbai dated 16/01/2025 in ITANo 4901/Mum/2024 held that “if advance /investment made by the assessee to its sister concern interest for the purpose of commercial expediency, no disallowance of interest can be made as the expenditure expanded for the purpose of business u/s 36 and 37 of I…

M/S. Thiruvalluvar Textiles Pvt. Ltd., Rasipuram vs. ACIT, Central Circle-1(1), Chennai

In the result, the appeal of the assessee is allowed for A

ITA 1734/CHNY/2025[2013-14]Status: DisposedITAT Chennai04 Nov 2025AY 2013-14

Bench: Shri George George K & Shri S.R.Raghunatha

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Shri. Shiva Srinivas, CIT
Section 11

…nded, not necessity and with a view to direct and immediate benefit, but voluntarily and on the grounds of commercial expediency and in order to indirectly facilitate the carrying on the business as held in the case of CIT vs Chandulal Keshavlal & Co (1960) 38 ITR 601. 21. In the case of ACIT vs T Bhimjyani Realty P Ltd ITAT Mumbai dated 16/01/2025 in ITANo 4901/Mum/2024 held that “if advance /investment made by the assessee to its sister concern interest for the purpose of commercial expediency, no disallowance of interest can be made as the expenditure expanded for the purpose of business u/s 36 and 37 of I…

Rama Kant Saboo, Jaipur vs. ACIT Circle 7, Baba Siddhanatha Bhawan

In the result, the appeal of the assessee is dismissed

ITA 1490/JPR/2024[2018-19]Status: DisposedITAT Jaipur28 Oct 2025AY 2018-19
For Appellant: Shri Ashok Kanodia, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 143Section 234Section 57

…ourt in CIT v. Rajendra Prasad Moody (1978) 115 ITR 519 (SC) held that it is not necessary that expenditure must result in income; it is sufficient if the expenditure is incurred with a view to earn income. Similarly, in Eastern Investments Ltd. v. CIT (1951) 20 ITR 1 (SC), the Apex Court  observed that an expenditure need not yield immediate profits, but must be connected with or incidental to the earning of income. In the present case, the exchange loss directly arises from remittance and  reconversion of funds through authorized banking channels, and represents a commercial incident of the transaction, not a…

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)

…-tax-III (ITA No. 603/2014) (Delhi High Court) Indian Visit.com (P.) Ltd. vs. Commissioner of Income-tax, Delhi-IV (ITA No. 1011/2008) (Delhi HC) CIT vs. Gujarat Mineral Development Corporation (1980) (132 ITR 377) (Guj) Eastern Investments Ltd. vs. CIT 1951 (20 ITR 1) (SC) S. A. Builders Ltd. vs. CIT (A) 2007 (288) ITR 1 (SC) Sri Venkata Satyanarayana Rice Mill Contractors Co. vs. CIT. [1997] 223 ITR 101 (SC) CIT vs. Dhanrajgirji Raja Narasingirji [1973] 91 ITR 544 (SC). Further the assessee has submitted that, "The assessee further submits that wherever the legislature intends to allow expenditure on deferred…

Huawei Telecommunications (India) Company Pvt. Ltd., Gurgaon vs. DCIT, Circle- 2(1), Gurgaon

In the result, the appeal of assessee is allowed

ITA 8260/DEL/2018[2014-15]Status: DisposedITAT Delhi10 Oct 2025AY 2014-15

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2014-15 Huawei Telecommunications Vs. Dcit, (India) Company Pvt. Ltd., Circle 2(1), 7Th Floor, Tower-A, Spaze-1- Gurgaon Tech Park, Sohna Road, (Haryana) Gurgaon, Haryana Pin: 122 001 Aabch1376E (Appellant) (Respondent)

For Appellant: S/Shri Deepak Chopra and AnkurFor Respondent: Shri Dharm Veer Singh, CIT (DR)
Section 142(1)Section 143(2)Section 144C(1)Section 92CSection 92C(3)

…T, Civil Appeal No. 12044/2016, judgement dated 22.07.2020 (Supreme Court) (Page 358 of convenience paperbook) (viii) Ad hoc disallowance of expenditure on account of incidental third party benefit is impermissible (ix) CIT v. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC) (Page 367 of convenience paperbook) (x) Sassoon J. David & Co. (P.) Ltd. v. CIT (118 ITR 261) (SC) (Page 379 of convenience paperbook) (xi) CIT v. Adidas India Marketing (P.) Ltd. (2010) 195 taxman 256 (Delhi) (Page 382-383 of convenience paperbook) (xii) CIT v. Agra Bevrages Corporation (P.) Ltd. (2011) 11 taxmann.com 350 (Delhi) (Page 388 o…

Jayaram Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(4), Bengaluru

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

ITA 711/BANG/2025[2021-22]Status: DisposedITAT Bangalore09 Oct 2025AY 2021-22

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

…ot apply. Since the assessee had shown exclusive business use, the disallowance could not be sustained. . ITA No.705 - 711/Bang/2025 Page 12 of 36 11.5 The learned AR also referred to the Hon’ble Supreme Court ruling in Eastern Investments Ltd. reported in 20 ITR 1 to argue that it is not necessary that every business expenditure must directly result in immediate income or profit; it is sufficient if the expenditure helps in brand building and long-term business advantage. 11.6 Finally, the learned AR submitted that the findings of the CIT(A) that no clear evidence was produced was incorrect because photograph…

Jayarama Reddy Boopesh Reddy, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle 2(4), Bengaluru

ITA 706/BANG/2025[2014-15]Status: DisposedITAT Bangalore09 Oct 2025AY 2014-15

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

For Appellant: Shri Bharat, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 132Section 132(4)Section 153A

…s of section 38(2) relating to mixed use did not apply. Since the assessee had shown exclusive business use, the disallowance could not be sustained. 11.5 The learned AR also referred to the Hon'ble Supreme Court ruling in Eastern Investments Ltd. reported in 20 ITR 1 to argue that it is not necessary that every business expenditure must directly result in immediate income or profit; it is sufficient if the expenditure helps in brand building and long-term business advantage. 11.6 Finally, the learned AR submitted that the findings of the CIT(A) that no clear evidence was produced was incorrect because photograph…

Ramamurthy Praveen Chandra, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

ITA 622/BANG/2025[2016-17]Status: DisposedITAT Bangalore29 Sept 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Sankar Ganesh D, Add. CIT(DR)(ITAT), Bangalore
Section 132Section 143Section 153Section 153ASection 153CSection 250

…David it Co., [P] Ltd., Vs. CIT, 118 ITR 261  M/s. Bombay Steam Navigation Company, reported in 56 ITR 52  CIT Vs. Abhoyjan Tea Estate [P] Ltd. 110 ITR 251  Eastern Investments Ltd Vs. CIT [1951] 20 ITR 1 [SC];  CIT Vs. Chaandulal Keshavlal & Co., [1960] 38 ITR 601 [SC];  CIT Vs. Nainital Bank limited [1966] 62 ITR 638 [SC];  Sri Venkata Sathyanarayana Rice Mill Contractors Co. Vs. CIT [1997] 223 ITR 101 [SC]; 12. On the other hand, learned DR relied on the Orders of the lower authorities and submitted that the documents were found during the search of M/s. Assetz Infrastructure Pvt. Ltd., and pertains and…

Ramamurthy Praveen Chandra, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

ITA 621/BANG/2025[2015-16]Status: DisposedITAT Bangalore29 Sept 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Sankar Ganesh D, Add. CIT(DR)(ITAT), Bangalore
Section 132Section 143Section 153Section 153ASection 153CSection 250

…David it Co., [P] Ltd., Vs. CIT, 118 ITR 261  M/s. Bombay Steam Navigation Company, reported in 56 ITR 52  CIT Vs. Abhoyjan Tea Estate [P] Ltd. 110 ITR 251  Eastern Investments Ltd Vs. CIT [1951] 20 ITR 1 [SC];  CIT Vs. Chaandulal Keshavlal & Co., [1960] 38 ITR 601 [SC];  CIT Vs. Nainital Bank limited [1966] 62 ITR 638 [SC];  Sri Venkata Sathyanarayana Rice Mill Contractors Co. Vs. CIT [1997] 223 ITR 101 [SC]; 12. On the other hand, learned DR relied on the Orders of the lower authorities and submitted that the documents were found during the search of M/s. Assetz Infrastructure Pvt. Ltd., and pertains and…

Ramamurthy Praveen Chandra, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

ITA 620/BANG/2025[2014-15]Status: DisposedITAT Bangalore29 Sept 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Sankar Ganesh D, Add. CIT(DR)(ITAT), Bangalore
Section 132Section 143Section 153Section 153ASection 153CSection 250

…David it Co., [P] Ltd., Vs. CIT, 118 ITR 261  M/s. Bombay Steam Navigation Company, reported in 56 ITR 52  CIT Vs. Abhoyjan Tea Estate [P] Ltd. 110 ITR 251  Eastern Investments Ltd Vs. CIT [1951] 20 ITR 1 [SC];  CIT Vs. Chaandulal Keshavlal & Co., [1960] 38 ITR 601 [SC];  CIT Vs. Nainital Bank limited [1966] 62 ITR 638 [SC];  Sri Venkata Sathyanarayana Rice Mill Contractors Co. Vs. CIT [1997] 223 ITR 101 [SC]; 12. On the other hand, learned DR relied on the Orders of the lower authorities and submitted that the documents were found during the search of M/s. Assetz Infrastructure Pvt. Ltd., and pertains and…

Ramamurthy Praveen Chandra, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

ITA 619/BANG/2025[2013-14]Status: DisposedITAT Bangalore29 Sept 2025AY 2013-14

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Sankar Ganesh D, Add. CIT(DR)(ITAT), Bangalore
Section 132Section 143Section 153Section 153ASection 153CSection 250

…David it Co., [P] Ltd., Vs. CIT, 118 ITR 261  M/s. Bombay Steam Navigation Company, reported in 56 ITR 52  CIT Vs. Abhoyjan Tea Estate [P] Ltd. 110 ITR 251  Eastern Investments Ltd Vs. CIT [1951] 20 ITR 1 [SC];  CIT Vs. Chaandulal Keshavlal & Co., [1960] 38 ITR 601 [SC];  CIT Vs. Nainital Bank limited [1966] 62 ITR 638 [SC];  Sri Venkata Sathyanarayana Rice Mill Contractors Co. Vs. CIT [1997] 223 ITR 101 [SC]; 12. On the other hand, learned DR relied on the Orders of the lower authorities and submitted that the documents were found during the search of M/s. Assetz Infrastructure Pvt. Ltd., and pertains and…

Nv Projects Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 1(2)(2), Mumbai

In the result, appeal of the assessee is allowed and appeal of the

ITA 1418/MUM/2025[2017-18]Status: DisposedITAT Mumbai18 Sept 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Vijay Mehta, A/RFor Respondent: Shri Satyaprakash R. Singh, CIT, D/R
Section 36(1)(iii)

…e on the decisions of the Hon'ble High Court of Gujarat in the case of Deputy Commissioner Of Income-Tax vs Core Healthcare Ltd [2001]251 ITR 61(Guj) and the Hon'ble Supreme Court in the case of Eastern Investments Limited v. Commissioner of Income-tax (1951) 20 ITR 1 (SC). The ld. D/R placed strong reliance on the assessment order and the order of the ld. CIT(A) and read the operative part. 6. We have carefully considered the orders of the authorities below and the judicial decisions relied upon by the ld. Counsel. The undisputed facts are that the articles of association of the assessee company authorises the a…

DCIT-5(2)(1), Mumbai vs. N V Project Private Limited, Mumbai

In the result, appeal of the assessee is allowed and appeal of the

ITA 1025/MUM/2025[2017-18]Status: DisposedITAT Mumbai18 Sept 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Vijay Mehta, A/RFor Respondent: Shri Satyaprakash R. Singh, CIT, D/R
Section 36(1)(iii)

…e on the decisions of the Hon'ble High Court of Gujarat in the case of Deputy Commissioner Of Income-Tax vs Core Healthcare Ltd [2001]251 ITR 61(Guj) and the Hon'ble Supreme Court in the case of Eastern Investments Limited v. Commissioner of Income-tax (1951) 20 ITR 1 (SC). The ld. D/R placed strong reliance on the assessment order and the order of the ld. CIT(A) and read the operative part. 6. We have carefully considered the orders of the authorities below and the judicial decisions relied upon by the ld. Counsel. The 5 undisputed facts are that the articles of association of the assessee company authorises the…

Radhakishan Beniwal, Jaipur vs. Deputy Commissioner of Income Tax, Circle 1, Jaipur

In the result, the appeal filed by the assessee in ITA no

ITA 695/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Sept 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CA &For Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 144Section 147rSection 148Section 148ASection 194CSection 251Section 68

…d in the following paragraphs, in light of the aforesaid principles. The expenditure must be incurred wholly and exclusively for the purpose of business or profession It has been held by Hon'ble Supreme Court in the case of CIT vs Chandulal Keshavlal [1960] 38 ITR 601 (SC), that commercial expediency has to be emphasized on for deciding whether payment of money is a deductible expenditure. In the case of CIT vs Kirloskar Tractors Limited [1998] 231 ITR 849 (Bom), it was held that the purpose of the expenditure and the effect should be considered from a common sense angle having due regard to the business realit…

Radhakishna Beniwal, Jaipur vs. Deputy Commissioner of Income Tax, Circle 1, Jaipur

In the result, the appeal filed by the assessee in ITA no

ITA 694/JPR/2025[2015-16]Status: DisposedITAT Jaipur10 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CA &For Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 144Section 147rSection 148Section 148ASection 194CSection 251Section 68

…d in the following paragraphs, in light of the aforesaid principles. The expenditure must be incurred wholly and exclusively for the purpose of business or profession It has been held by Hon'ble Supreme Court in the case of CIT vs Chandulal Keshavlal [1960] 38 ITR 601 (SC), that commercial expediency has to be emphasized on for deciding whether payment of money is a deductible expenditure. In the case of CIT vs Kirloskar Tractors Limited [1998] 231 ITR 849 (Bom), it was held that the purpose of the expenditure and the effect should be considered from a common sense angle having due regard to the business realit…

Shri Jagdishbhai Gordhanbhai Doabariya, Rajkot vs. The Pr. CIT-1, Rajkot

In the result, appeal filed by the assessee, is allowed

ITA 142/RJT/2023[2018-19]Status: DisposedITAT Rajkot29 Aug 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.142/Rjt/2023 "नधा"रणवष"/ Assessment Year: 2018-19 Jagdishbhai Gordhanbhai Dobariya The Pr.Cit-1 बनाम “Ramdev”2, Jivnath Park,B/H. Panchvati Aayakar Bhavan, Race Hall,Panchvati Main Road,Nr.Gandhi Vs. Course Ring Road, School,Rajkot 360 001 Rajkot. Pan : Abrpd8654R (अपीलाथ"/Assessee) (""यथ"/Respondent) :

For Appellant: Shri Rajendra Singhal, ld.ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR
Section 143(3)Section 263Section 57

…clusion that to bring a case within the section, it is not necessary that any income should in fact have been earned as a result of the expenditure. It may be pointed out that an identical view was taken by this court in Eastern Investments Ltd. v. CIT [1951] 20 ITR 1 , 4 (SC), where interpreting the corresponding provision in s. 12(2) of the Indian I.T. Act, 1922, which was ipsissima verba in the same terms as s. 57(iii), Bose J., speaking on behalf of the court, observed: "It is not necessary to show that the expenditure was a profitable one or that in fact any profit was earned." ITA No.142 /RJT/2023 Shri Jag…

Vinay Sanwarmal Nangalia, Mumbai vs. Income Tax Officer, Mumbai

In the result, grounds of appeal of assessee are partly allowed

ITA 2868/MUM/2023[2016-17]Status: DisposedITAT Mumbai18 Aug 2025AY 2016-17

Bench: Shri Pawan Singh& Ms. Padmavathy S(Physical Hearing) Vinay Sanwarmal Nangalia Ito, Ward – 17(3)(5), Mumbai 114 Satnam Apartments, Vs Aayakar Bhavan, 93, Cuffe Parade, Maharishi Karve Road, Mumbai-400005. Mumbai-400020. [Pan: Aadpn6491K] Appellant / Assessee Respondent / Revenue

Section 254(1)

…its that he has given a written note on his submission which may be considered. To support his submission, the ld. AR of the assessee relied upon the decision in:  Sassoon J. David & Co. Pvt. Ltd. (1979) 1 Taxman 485 (SC)  Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC)  CIT vs Chandulal Deshavlal & Co. and Sasson J. David & Co. (P) Ltd. vs CIT 2  Great Value Foods (ITA No. 314/Asr/2011  IREO Waterfront Pvt. Ltd. (ITA No. 2849 & 2850/Del/2016  Rajeev Verma vs ACIT (ITA No. 6143/Del/2016)  R.K. Trading Company (ITA No. 2609/Ahd/2017)  ISGEC Heavy Engineering Ltd. vs DCIT (ITA No. 798/Chd/2019)  Bharat…

Cobol Technologies P.Ltd, New Delhi vs. ACIT, Central Circle-18, New Delhi

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 5505/DEL/2018[2014-15]Status: DisposedITAT Delhi25 Apr 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…indirect benefits have occured to the third party. In support of the submission, the reliance is placed on following decision CIT vs. Chandulal 15 Sahara India Commercial Corporation Ltd. ITA No. 1977/DEL/2013 (A.Y.2009-10) & Other Appeals Keshavlal & Co, 38 ITR 601 (SC); & Pepsico India Holdings vs. Addl. CIT, 100 taxmann.com 159 (Del. ITAT). 13.2. In so far as, total quantum of advertisement expenditure in the form of sponsorship fee paid to the BCCI, the same is not in dispute. It is only the apportionment of the expenditure amongst the Sahara Group entities which is subject matter of dispute. The assesse…