(i) CIT v. Rane (Madras) Ltd.

293 ITR 459High Court2007#6963 most cited

What is (i) CIT v. Rane (Madras) Ltd. authority for?

Expenditures are considered revenue in nature and deserve to be allowed when they meet the criteria for such deductibility.

16

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2023.

Also referred to as

CIT v. Rane (Madras) Ltd. · 293 ITR 459 · revenue expenditure · allowability of expenses · income tax act · Madras High Court

Sections most often in play

Section 143(3)Section 144C(13)Section 14ASection 41(1)Section 80A(6)Section 80IASection 80IA(8)

Judgments citing (i) CIT v. Rane (Madras) Ltd.

Acc Limited, Mumbai vs. DCIT (Ltu), Mumbai

In the result, appeal filed by department is dismissed

ITA 800/MUM/2022[2013-14]Status: DisposedITAT Mumbai30 Jun 2023AY 2013-14

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms Kavitha Rajagopal, Hon'Blem/S. Acc Limited V. Dcit (Ltu) 121, Cement House, M.K. Road 29Th Floor, Center-1 Churchgate, Mumbai-400020 World Trade Centre, Cuffe Parade Mumbai - 400005 Pan: Aaact1507C (Appellant) (Respondent) Asst. Cit – 3(4) V. M/S. Acc Limited 29Th Floor, Center-1 Cement House,121, M.K. Road World Trade Centre, Cuffe Parade Churchgate, Mumbai-400020 Mumbai-400005 Pan: Aaact1507C (Appellant) (Respondent)

Section 14A

…of Ld.CIT(A). The Ld. AR has relied upon submissions filed before Ld.CIT(A) and contended that such expenditures are revenue in nature hence same deserves to be allowed. The Ld. AR has mainly relied upon the following decisions: (i) CIT v. Rane (Madras) Ltd. (293 ITR 459) (Madras) Page No.103 ITA NO.1171/MUM/2022 (A.Y: 2013-14) M/s. ACC Limited (ii) CIT v. Relaxo Footwears Ltd. (293 ITR 231) (Delhi High Court) (iii) Reliance Footprint Ltd. v. ACIT [ITA NO. 5997 of 2011 (Mumbai Tribunal)] (iv) ACIT v. Gravis Foods (P.) Ltd. [ITA No. 1051 of 2013 (Mumbai Tribunal) 71. The Ld DR has relied upon finding of assessing…

Asst. Commissioner of Income Tax-3(4), Mumbai-400005 vs. M/S. Acc Limited, Mumbai-400020

In the result, appeal filed by department is dismissed

ITA 1171/MUM/2022[2013-14]Status: DisposedITAT Mumbai30 Jun 2023AY 2013-14

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms Kavitha Rajagopal, Hon'Blem/S. Acc Limited V. Dcit (Ltu) 121, Cement House, M.K. Road 29Th Floor, Center-1 Churchgate, Mumbai-400020 World Trade Centre, Cuffe Parade Mumbai - 400005 Pan: Aaact1507C (Appellant) (Respondent) Asst. Cit – 3(4) V. M/S. Acc Limited 29Th Floor, Center-1 Cement House,121, M.K. Road World Trade Centre, Cuffe Parade Churchgate, Mumbai-400020 Mumbai-400005 Pan: Aaact1507C (Appellant) (Respondent)

Section 14A

…of Ld.CIT(A). The Ld. AR has relied upon submissions filed before Ld.CIT(A) and contended that such expenditures are revenue in nature hence same deserves to be allowed. The Ld. AR has mainly relied upon the following decisions: (i) CIT v. Rane (Madras) Ltd. (293 ITR 459) (Madras) Page No.103 ITA NO.1171/MUM/2022 (A.Y: 2013-14) M/s. ACC Limited (ii) CIT v. Relaxo Footwears Ltd. (293 ITR 231) (Delhi High Court) (iii) Reliance Footprint Ltd. v. ACIT [ITA NO. 5997 of 2011 (Mumbai Tribunal)] (iv) ACIT v. Gravis Foods (P.) Ltd. [ITA No. 1051 of 2013 (Mumbai Tribunal) 71. The Ld DR has relied upon finding of assessing…

DCIT(Ltu) - 1, Mumbai vs. Acc Ltd., Mumbai

In the result, appeal filed by assessee is partly allowed

ITA 3176/MUM/2019[2009-10]Status: DisposedITAT Mumbai28 Feb 2023AY 2009-10

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 147Section 148Section 151Section 55A

…f Ld.CIT(A). The Ld. AR has relied upon submissions filed before Ld.CIT(A) and contended that such expenditures are revenue in nature hence same deserves to be allowed. The Ld. AR has mainly relied upon the following decisions: (i) CIT v. Rane (Madras) Ltd. (293 ITR 459) (Madras) (ii) CIT v. Relaxo Footwears Ltd. (293 ITR 231) (Delhi High Court) (iii) Reliance Footprint Ltd. v. ACIT [ITA NO. 5997 of 2011 (Mumbai Tribunal)] (iv) ACIT v. Gravis Foods (P.) Ltd. [ITA No. 1051 of 2013 (Mumbai Tribunal) 71. The Ld DR has relied upon finding of assessing officer and argued that order of Assessing Officer may be restor…

Acc Ltd., Mumbai vs. DCIT(Ltu) - 1, Mumbai

In the result, appeal filed by assessee is partly allowed

ITA 3136/MUM/2019[2009-10]Status: DisposedITAT Mumbai28 Feb 2023AY 2009-10

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 147Section 148Section 151Section 55A

…f Ld.CIT(A). The Ld. AR has relied upon submissions filed before Ld.CIT(A) and contended that such expenditures are revenue in nature hence same deserves to be allowed. The Ld. AR has mainly relied upon the following decisions: (i) CIT v. Rane (Madras) Ltd. (293 ITR 459) (Madras) (ii) CIT v. Relaxo Footwears Ltd. (293 ITR 231) (Delhi High Court) (iii) Reliance Footprint Ltd. v. ACIT [ITA NO. 5997 of 2011 (Mumbai Tribunal)] (iv) ACIT v. Gravis Foods (P.) Ltd. [ITA No. 1051 of 2013 (Mumbai Tribunal) 71. The Ld DR has relied upon finding of assessing officer and argued that order of Assessing Officer may be restor…

Acc Ltd., Mumbai vs. DCIT(Ltu) - 1, Mumbai

In the result, appeal filed by assessee is partly allowed

ITA 3135/MUM/2019[2009-10]Status: DisposedITAT Mumbai28 Feb 2023AY 2009-10

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 147Section 148Section 151Section 55A

…f Ld.CIT(A). The Ld. AR has relied upon submissions filed before Ld.CIT(A) and contended that such expenditures are revenue in nature hence same deserves to be allowed. The Ld. AR has mainly relied upon the following decisions: (i) CIT v. Rane (Madras) Ltd. (293 ITR 459) (Madras) (ii) CIT v. Relaxo Footwears Ltd. (293 ITR 231) (Delhi High Court) (iii) Reliance Footprint Ltd. v. ACIT [ITA NO. 5997 of 2011 (Mumbai Tribunal)] (iv) ACIT v. Gravis Foods (P.) Ltd. [ITA No. 1051 of 2013 (Mumbai Tribunal) 71. The Ld DR has relied upon finding of assessing officer and argued that order of Assessing Officer may be restor…

Jindal Steel & Power Ltd., New Delhi vs. ACIT, Hisar

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

ITA 893/DEL/2014[2009-10]Status: DisposedITAT Delhi29 Apr 2019AY 2009-10

Bench: Sh. Bhavnesh Saini & Sh. N. S. Sainiita No. 893/Del/2014 : Asstt. Year : 2009-10 Jindal Steel & Power Ltd., Vs Asstt. Commissioner Of Jindal Centre, 12, Bhikaji Cama Income Tax, Hisar Circle, Place, New Delhi-110066 Hisar (Appellant) (Respondent) Pan No. Aaacj7079D Assessee By : Sh. Salil Kapoor, Adv., Sh. Sumit Lal Chandani, Adv., Ms. Ananya Kapoor, Adv. & Ms. Pallavi Saigal, Adv. Revenue By : Sh. Sanjay I. Bara, Cit Dr Date Of Hearing :05.03.2019 Date Of Pronouncement : 29.04.2019 Order Per N. S. Saini: This Is An Appeal Filed By The Assessee Against The Order Of Assessing Officer U/S 143(3)/144C(13) Of The Income Tax Act, 1961 Dated 29.10.2018 For Assessment Years 2013-14

For Appellant: Sh. Salil Kapoor, AdvFor Respondent: Sh. Sanjay I. Bara, CIT DR
Section 143(3)Section 144CSection 80Section 80I

…td. (No. 3): 200 ITR 341(Delhi) " CIT Vs. Triveni Engineering and Industries Limited. : 181Taxman 5 (Delhi) " CIT Vs. Relaxo Footwears Ltd. : 293 ITR 231 (Delhi) " CIT Vs. Usha Iron & Ferro Metal Corp. Ltd. : 296 ITR 140 (Delhi) " CIT Vs. Rane (Madras) Ltd. : 293 ITR 459 (Delhi) " Indo rama Synthetics (I) Ltd.Vs. CIT: 228 CTR 278 (Delhi) " Jay Engineering works ltd. Vs. CIT: 311 ITR 405 (Delhi) " CIT Vs. Monnet Industries Ltd. : 221 CTR 266 (Delhi) " CIT Vs. havells India Limited: 352 ITR 376 (Delhi) 137. It is thus settled position that expenditure incurred for the purpose of expansion/extension of the existing…

Media Features (India) Pvt. Ltd., New Delhi vs. ITO, Ward- 16(3), New Delhi

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

ITA 4682/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Nov 2017AY 2012-13

Bench: Shri B.P. Jain

For Appellant: Shri S.K. Chaturvedi, CAFor Respondent: Shri Atiq Ahmed Sr. DR
Section 192Section 194JSection 40Section 40A(2)

…ses incurred by the assessee for the setting up of the new unit which was a part of the existing business were therefore, to be allowed as a revenue expenditure.” 11. Similarly Madras High Court has also held the same in the case of CIT v. Rane (Madras) Ltd. 293 ITR 459 (Mad) 12. In that view of the matter, I am of the view that the ld. CIT(A) is not justified in confirming the addition made by the Assessing Officer and the same is directed to be deleted. Thus ground No. 3 is allowed. 5. In the result, the appeal of the assessee in ITA No. 4682/DEL/2017 is partly allowed. The order is pronounced in the open co…

Sundaram Fasteners Limited, Chennai vs. ACIT, Chennai

In the result, the appeals of the assessee in ITA

ITA 1166/CHNY/2013[2008-2009]Status: DisposedITAT Chennai30 Sept 2016AY 2008-2009

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

For Appellant: Shri. R. Vijayaraghavan, Adv

…y specific reasons why he was rejecting the contention taken by the assessee. As per the ld. Authorised Representative by virtue of judgment of jurisdictional High Court in the cases of CIT vs. Gemini Arts Pvt. Ltd. 254 ITR 201 and CIT vs. Rane (Madras) Ltd 293 ITR 459 such lease advance payment could only be considered as Revenue in nature. 10. Per contra, the ld. Departmental Representative relying on the judgment dated 4th December, 2006 of Apex Court in the ITA Nos.591 & 675/12, 1165, :- 5 -: 1166, 1171 & 1172/13. Enterprising Enterprises vs. DCIT 293 ITR 437(SC) submitted that payment for acquiring leas…

Sundaram Fasteners Limited, Chennai vs. ACIT, Chennai

In the result, the appeals of the assessee in ITA

ITA 1165/CHNY/2013[2007-2008]Status: DisposedITAT Chennai30 Sept 2016AY 2007-2008

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

For Appellant: Shri. R. Vijayaraghavan, Adv

…y specific reasons why he was rejecting the contention taken by the assessee. As per the ld. Authorised Representative by virtue of judgment of jurisdictional High Court in the cases of CIT vs. Gemini Arts Pvt. Ltd. 254 ITR 201 and CIT vs. Rane (Madras) Ltd 293 ITR 459 such lease advance payment could only be considered as Revenue in nature. 10. Per contra, the ld. Departmental Representative relying on the judgment dated 4th December, 2006 of Apex Court in the ITA Nos.591 & 675/12, 1165, :- 5 -: 1166, 1171 & 1172/13. Enterprising Enterprises vs. DCIT 293 ITR 437(SC) submitted that payment for acquiring leas…

ACIT, Chennai vs. M/S. Sundaram Fasterners Ltd., Chennai

In the result, the appeals of the assessee in ITA

ITA 675/CHNY/2012[2006-07]Status: DisposedITAT Chennai30 Sept 2016AY 2006-07

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

For Appellant: Shri. R. Vijayaraghavan, Adv

…y specific reasons why he was rejecting the contention taken by the assessee. As per the ld. Authorised Representative by virtue of judgment of jurisdictional High Court in the cases of CIT vs. Gemini Arts Pvt. Ltd. 254 ITR 201 and CIT vs. Rane (Madras) Ltd 293 ITR 459 such lease advance payment could only be considered as Revenue in nature. 10. Per contra, the ld. Departmental Representative relying on the judgment dated 4th December, 2006 of Apex Court in the ITA Nos.591 & 675/12, 1165, :- 5 -: 1166, 1171 & 1172/13. Enterprising Enterprises vs. DCIT 293 ITR 437(SC) submitted that payment for acquiring leas…

Sundram Fasteners Limited, Chennai vs. Addl.CIT, Chennai

In the result, the appeals of the assessee in ITA

ITA 591/CHNY/2012[2006-07]Status: DisposedITAT Chennai30 Sept 2016AY 2006-07

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

For Appellant: Shri. R. Vijayaraghavan, Adv

…y specific reasons why he was rejecting the contention taken by the assessee. As per the ld. Authorised Representative by virtue of judgment of jurisdictional High Court in the cases of CIT vs. Gemini Arts Pvt. Ltd. 254 ITR 201 and CIT vs. Rane (Madras) Ltd 293 ITR 459 such lease advance payment could only be considered as Revenue in nature. 10. Per contra, the ld. Departmental Representative relying on the judgment dated 4th December, 2006 of Apex Court in the ITA Nos.591 & 675/12, 1165, :- 5 -: 1166, 1171 & 1172/13. Enterprising Enterprises vs. DCIT 293 ITR 437(SC) submitted that payment for acquiring leas…

Hinduja Foundries Ltd., Chennai vs. ACIT, Chennai

In the result, I.T.A. Nos

ITA 1593/CHNY/2015[2010-11]Status: DisposedITAT Chennai19 Feb 2016AY 2010-11

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1590, 1591, 1592 & 1593/Mds/2015 "नधा"रण वष" / Assessment Years : 2006-07, 2007-08, 2009-10 & 2010-11

For Appellant: Sh. R. Vijayaraghavan, AdvocateFor Respondent: Sh. Pathlavath Peerya, CIT
Section 32(1)(ii)

…business. The new unit is also under the same management. Therefore, the expenditure claimed by the assessee has to be allowed as revenue expenditure. The Ld.counsel placed his reliance on the judgments of Madras High Court in CIT v. Rane (Madras) Ltd. (2007) 293 ITR 459 and in CIT v. Sakthi Sugars Ltd. (2011) 339 ITR 400. 9. On the contrary, Sh. Pathlavath Peerya, the Ld. Departmental Representative, submitted that the assessee’s balance sheet showed the capital work-in-progress at `1543/- lakhs which included the fixed assets schedule. According to the Ld. D.R., the new units established by the assessee at Sri…

Hinduja Foundries Ltd., Chennai vs. ACIT, Chennai

In the result, I.T.A. Nos

ITA 1592/CHNY/2015[2009-10]Status: DisposedITAT Chennai19 Feb 2016AY 2009-10

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1590, 1591, 1592 & 1593/Mds/2015 "नधा"रण वष" / Assessment Years : 2006-07, 2007-08, 2009-10 & 2010-11

For Appellant: Sh. R. Vijayaraghavan, AdvocateFor Respondent: Sh. Pathlavath Peerya, CIT
Section 32(1)(ii)

…business. The new unit is also under the same management. Therefore, the expenditure claimed by the assessee has to be allowed as revenue expenditure. The Ld.counsel placed his reliance on the judgments of Madras High Court in CIT v. Rane (Madras) Ltd. (2007) 293 ITR 459 and in CIT v. Sakthi Sugars Ltd. (2011) 339 ITR 400. 9. On the contrary, Sh. Pathlavath Peerya, the Ld. Departmental Representative, submitted that the assessee’s balance sheet showed the capital work-in-progress at `1543/- lakhs which included the fixed assets schedule. According to the Ld. D.R., the new units established by the assessee at Sri…

Hinduja Foundries Ltd., Chennai vs. ACIT, Chennai

In the result, I.T.A. Nos

ITA 1591/CHNY/2015[2007-08]Status: DisposedITAT Chennai19 Feb 2016AY 2007-08

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1590, 1591, 1592 & 1593/Mds/2015 "नधा"रण वष" / Assessment Years : 2006-07, 2007-08, 2009-10 & 2010-11

For Appellant: Sh. R. Vijayaraghavan, AdvocateFor Respondent: Sh. Pathlavath Peerya, CIT
Section 32(1)(ii)

…business. The new unit is also under the same management. Therefore, the expenditure claimed by the assessee has to be allowed as revenue expenditure. The Ld.counsel placed his reliance on the judgments of Madras High Court in CIT v. Rane (Madras) Ltd. (2007) 293 ITR 459 and in CIT v. Sakthi Sugars Ltd. (2011) 339 ITR 400. 9. On the contrary, Sh. Pathlavath Peerya, the Ld. Departmental Representative, submitted that the assessee’s balance sheet showed the capital work-in-progress at `1543/- lakhs which included the fixed assets schedule. According to the Ld. D.R., the new units established by the assessee at Sri…

Hinduja Foundries Ltd., Chennai vs. ACIT, Chennai

In the result, I.T.A. Nos

ITA 1590/CHNY/2015[2006-07]Status: DisposedITAT Chennai19 Feb 2016AY 2006-07

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1590, 1591, 1592 & 1593/Mds/2015 "नधा"रण वष" / Assessment Years : 2006-07, 2007-08, 2009-10 & 2010-11

For Appellant: Sh. R. Vijayaraghavan, AdvocateFor Respondent: Sh. Pathlavath Peerya, CIT
Section 32(1)(ii)

…business. The new unit is also under the same management. Therefore, the expenditure claimed by the assessee has to be allowed as revenue expenditure. The Ld.counsel placed his reliance on the judgments of Madras High Court in CIT v. Rane (Madras) Ltd. (2007) 293 ITR 459 and in CIT v. Sakthi Sugars Ltd. (2011) 339 ITR 400. 9. On the contrary, Sh. Pathlavath Peerya, the Ld. Departmental Representative, submitted that the assessee’s balance sheet showed the capital work-in-progress at `1543/- lakhs which included the fixed assets schedule. According to the Ld. D.R., the new units established by the assessee at Sri…

Hinduja Foundries Ltd., Chennai vs. ACIT, Chennai

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

ITA 1561/CHNY/2015[2007-08]Status: DisposedITAT Chennai19 Feb 2016AY 2007-08

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.1561/Mds/2015 "नधा"रण वष" / Assessment Year : 2007-08 M/S Hinduja Foundries Ltd., The Assistant Commissioner Of (Formerly Known As M/S Ennore V. Income Tax, Foundries Ltd.), Corporate Circle 2, Kathivakkam High Road, Ennore, Chennai - 600 034. Chennai - 600 034 Pan : Aaace 1078 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Sh. R. Vijayaraghavan, AdvocateFor Respondent: Sh. Pathlavath Peerya, CIT
Section 36(1)(iii)

…prior to commencement of operation of industry should be capitalized. Therefore, the Assessing Officer found that the expenses cannot be allowed as revenue expenditure. Placing reliance on the judgment of Madras High Court in CIT v. Rane (Madras) Limited (293 ITR 459), the Ld.counsel submitted that the expenditure and wages connected with expansion of the business has to be allowed as business expenditure. According to the Ld. counsel, because of interconnection of management, financial, administrative and production aspects, the expenditure has to be construed as revenue in nature. A similar view has been…

(i) CIT v. Rane (Madras) Ltd. (293 ITR 459) — Cited in 16 Judgments | BharatTax