How many judgments cite Jamshedpur Motor Accessories Stores v. CIT?

140 judgments on BharatTax cite Jamshedpur Motor Accessories Stores v. CIT (72 ITR 612), spanning 2013 to 2026.

Which sections of the Income Tax Act does Jamshedpur Motor Accessories Stores v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 148, Section 147, Section 14A, Section 40A(2)(b), Section 142(2A).

Jamshedpur Motor Accessories Stores v. CIT

72 ITR 612Supreme Court of India1969#721 most cited

What is Jamshedpur Motor Accessories Stores v. CIT authority for?

The reasonableness of an expenditure for business purposes must be assessed from the businessman's perspective, not the revenue's, and the primary motive to earn income directly is not a prerequisite for its admissibility as a deduction.

140

judgments rely on this decision, according to BharatTax’s citation analysis of 367,518 Indian tax judgments — from 2013 to 2026.

Also referred to as

Jamshedpur Motor Accessories Stores v. CIT · expenditure admissibility · business purposes · reasonableness of expenditure · businessman's viewpoint · revenue's viewpoint · section 10(2)(xv) · commercial expediency

Sections most often in play

Section 143(3)Section 148 Section 147 Section 14A Section 40A(2)(b)Section 142(2A)Section 2(22)(e)Section 40(a)(ia)

Issues it is cited on

section 40(3)short deduction of tds interest on interest closely held company section 40a(2)(b)short deduction of tax amp expenditure section 92ba accumulated profits true and full disclosure related party transaction business expediency

Judgments citing Jamshedpur Motor Accessories Stores v. CIT

Asstt.Commissioner of Income Tax Circle-1, Nagpur vs. Vishnu Gilts Pvt.Lt, Nagpur

In the result, appeal filed by the Revenue is dismissed

ITA 237/NAG/2018[2012-13]Status: DisposedITAT Nagpur25 Oct 2024AY 2012-13

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Abhay AgrawalFor Respondent: Shri Abhay Y. Marathe

…e of an expenditure or an investment vide 6 M/s. Raghav Finvest Pvt. Ltd. ITA no.121/Nag./2020 CIT v. Dalmia Cement (254 ITR 377) (Delhi HC) approved by SC in 288 ITR 1, CIT v. Walchand & Co. (P.) Ltd. [1967] 65 ITR 381 (SC), J.K. Woollen Mfrs. v. CIT [1969] 72 ITR 612 (SC), Aluminium Corpn.of India Ltd. v. CIT [1972] 86 ITR 11 (SC) and CIT v. Panipat Woollen & General Mills Co. Ltd. [1976] 103 ITR 66 (SC). 4.8 During the course of appellate proceedings, the appellant was asked about applicability of provisions of section 56(2)(viib) of the Act. The appellant submitted that the aforesaid provision has been inser…

Magendra Singh Rathore, Alwar vs. DCIT Central Circle-2, Jaipur

In the result the appeal of the assessee is partly allowed

ITA 483/JPR/2024[2017-18]Status: DisposedITAT Jaipur23 Sept 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Mahendra Gargiya (Adv.) &For Respondent: Shri Anup Singh (Addl. CIT)

Section 143(3)Section 234ASection 36(1)(iii)Section 57

…o take care of its interest. The law is settled that the AO cannot sit on the arm chair of the businessman. The allowability of claimed interest therefore should have been allowed accordingly. For this proposition, kindly referJ.K. Woollen Mfg. vs. CIT [1969] 72 ITR 612 (SC). 5. Supporting Case Laws: 5.1In the facts of the present case, a useful reference can be made to the celebrated decision of Hon’ble Apex court in the case of S. A. Builders Ltd. Vs. CIT(A),Chandigarhreported in 288 ITR 1 where it was held as under: “18. We have considered the submission of the respective parties. The question involved in this…

Decent Industries P. Ltd., Bhopal vs. ITO-1(2), Bhopal

Appeal is partly allowed

ITA 356/IND/2023[2012-13]Status: DisposedITAT Indore20 Aug 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani(Virtual Hearing) Assessment Year: 2012-13 M/S Decent Industries Ito-1(2), Private Ltd, Bhopal 5Th Floor, Corporate Park, बनाम/ Db City Area Hills, Vs. Opp. M.P. Nagar Zone I, Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aaeca6271G Assessee By Ms. Shilpa Gupta & Shri N.K. Gupta Revenue By Shri V.K. Singh, Cit-Dr Date Of Hearing 04.06.2024 Date Of Pronouncement 20.08.2024

Section 133ASection 143(2)Section 147Section 148Section 14ASection 68

…nt businessman. The test of prudence by substituting its own view in place of the businessman's has not been approved by the Supreme Court in the decisions of CIT V/s. Walchand & Co. Pr. Ltd. [(1967) 65 ITR 381] and J.K. Woollen Manufacturers V/s. CIT [(1969) 72 ITR 612].” 12. Having submitted thus, Ld. AR also pointed out a legal lacuna in the action of lower-authorities. It is submitted that the assessee has received subscription from “A” & “J” through banking channel which were duly recorded in books of “A” & “J”. The companies “A” & “J” are ‘source’ for assessee and the assessee has filed ample evidences t…

Shri Rampriya Developers Private Limited, Hyderabad vs. Deputy Commissioner of Incometax, Circle-3(1), Hyderabad

In the result, appeal filed by the assessee is dismissed

ITA 1946/HYD/2017[1999-2000]Status: DisposedITAT Hyderabad14 Aug 2024AY 1999-2000

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.1946/Hyd/2017 (िनधा"रण वष"/Assessment Year: 1999-2000) Shri Rampriya Developers Vs. Dy. C. I. T. (P) Ltd Circle 3(1) Hyderabad Hyderabad Pan:Aajcs6629P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A.V. Raghuram, Advocate राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 09/07/2024 घोषणा की तारीख/Pronouncement: 14/08/2024 आदेश/Order

For Appellant: Shri A.V. Raghuram, AdvocateFor Respondent: : Shri Shakeer Ahmed, DR

Section 143(3)Section 14A

…ey honestly believes to be a fair estimate of the proper figure of assessment. 20. Now we consider the judgments cited by the learned AR. We do not see how these decisions help to the case of the assessee. The Apex Court in the case of JK Woollen Manufactures 72 ITR 612 (SC) clearly held that it is open to the Tribunal to come to a conclusion either that the alleged payment is not real or that it is not incurred by the assessee though it is to be adjudged from the point of view of the businessman and not of the IT Department. In the case under consideration, the issue of purchase price of shares of SVCL has been…

Crm Services India Private Limited, New Delhi vs. DCIT, Circle-4(2), New Delhi

The appeals of the assessee are allowed with consequential effect

ITA 1519/DEL/2022[2010-11]Status: DisposedITAT Delhi08 Apr 2024AY 2010-11

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Rajesh Kumar, CIT-DR

Section 254

…om the appellant’s point of view. Attention was drawn to the following judgments for supporting the aforsaid contentios; - CIT vs. Malayalam Plantations Limited: 53 ITR 140 (SC) - CIT v. Walchand& Co. etc. (1967) 65 ITR 381 - J K Woollen Manufacturers v. CIT: 72 ITR 612(SC) - CIT v. Birla Cotton Spg. And Wvg. Mills Ltd.: 82 ITR 166 (SC) - Madhav Prasad Jatia v. CIT U.P.: 118 ITR 200 (SC) - S.A. Builders Ltd. vs. CIT : 288 ITR 1 (SC) - CIT V. Bharti Televentures Ltd: 331 ITR 502 (Del) - CIT vs. Padmani Packaging (P) Ltd. : 155 Taxmann 268 (Del) - CIT v. Rockman Cycle Industries Ltd.: 331 ITR 401 (P&H) (FB) - CIT v…

Crm Services India Private Limited, New Delhi vs. DCIT, Circle-4(2), New Delhi

The appeals of the assessee are allowed with consequential effect

ITA 1518/DEL/2022[2009-10]Status: DisposedITAT Delhi08 Apr 2024AY 2009-10

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Rajesh Kumar, CIT-DR

Section 254

True-Man Consultants Pvt. Ltd., Kolkata vs. ITO, Ward-7(2), Kolkata.

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

ITA 1158/KOL/2023[2012-13]Status: DisposedITAT Kolkata23 Feb 2024AY 2012-13

Bench: Sri Rajpal Yadav & Dr. Manish Borad

Section 131Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 68

…ition of law that the test of prudence by substituting its own view in place of the businessman's has been disapproved by the Supreme Court in the decisions of CIT V/s. Walchand & Co. Pr. Ltd. [(1967) 65ITR 381] and J.K. Woollen Manufacturers V/s. CIT [(1969) 72 ITR 612]. That the Ld. CIT (A) has failed to appreciate the dictum of Hon'ble Allahabad High court in the matter of CIT v. S. Kamaljeet Singh [2005] Page 5 of 36 I.T.A. No.: 1158/KOL/2023 Assessment Year: 2012-13 True-Man Consultants Pvt. Ltd. 147 Taxman 18(AIL) their lordships, on the issue of discharge of assessee's onus in relation to a cash credit ap…

Phrama Corpn Inc Private Limited, Indore vs. ACIT Cirecle 4(1), Indore

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

ITA 303/IND/2023[2015-16]Status: DisposedITAT Indore30 Jan 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanipharma Corp Inc Private Ait, Circle 4(1) Ltd. Indore Plot No.49, Mr-11 Sk Compound -1, Lasudia Mori Vs. Dewas Naka, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaecp8775E Assessee By Shri Rajendra Khandelwal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 25.01.2024 Date Of Pronouncement 30.01.2024

Section 133(6)

…the ground that the commission agent has not responded to the notice issued by the AO. In support of his contention he has relied upon the following decisions: Page 3 of 6 ITANo.303/Ind/2023 Pharma Corpn Inc. Pvt. ltd. 1. J.K. Woollen Manufactures vs. CIT 72 ITR 612 2. Tirumala Seven Hills Pvt. Ltd. vs. JCIT Kolkata ITANo.782/Kol/2016 3. CIT vs. M/s Inbuilt Merchants Pvt. Ltd. GANo.3825 of 2013 (Cal) 4.Cheil India Pvt. ltd. vs. ITO in ITANo.6183/Del/2014 5. Thus, Ld. AR has submitted that when the assessee produced all the relevant details showing the payment of commission to the agents as well as sales made…

Gurcharan Singh Bhatia, New Delhi vs. ACIT Circle-47(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 3433/DEL/2019[2014-15]Status: DisposedITAT Delhi11 Jan 2024AY 2014-15

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasad:Assessment Year: 2014-15 Shri Gurcharan Singh Bhatia, Vs. Acit, C-9, Westend Colony, Circle 47(1), New Delhi-1100 21 New Delhi (Appellant) (Respondent) (Pan:Ahnpb4697E) Assessee By : S/Shri K. Sampath & V. Rajkumar, Advocates Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 29.11.2023 Date Of Pronouncement: 11.01.2024 Order Per Challa Nagendra Prasad:This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-16, New Delhi

For Appellant: S/Shri K. Sampath & V. RajkumarFor Respondent: Shri Amit Katoch, Sr. DR

Section 37(1)Section 68

…right to arrange his affairs according to his prudence and discretion. Any objection by the Revenue in this regard is inconsequential and redundant. The apex Court decisions in Walchand & Co. P. Ltd. (1967) 65 ITR 381 and J.K. 17 Woollen Manufacturers (1969) 72 ITR 612 stand solidly to support this proposition. 14) The CIT(A) s observation regarding the interest charge on the top up loan of Rs. 22.79 lacs from ICICI is ex facie erroneous, in as much as, the property has been acquired out of an interest bearing loans and so interest has rightly to be allowed against the business income resulting from the same. Ir…

Chems Deal Inc P Ltd., Indore vs. The CIT-1, Indore

In the result, the appeal of the assesse is allowed

ITA 166/IND/2023[2018-19]Status: DisposedITAT Indore30 Nov 2023AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Chems Deal Inc Pvt. Ltd. Pr. Cit-1 3Rd Floor Tulsi 622 Creater Indore Vs. Brajeshwari Colony Pipliahana Indore (Appellant / Assessee) (Revenue) Pan: Aadcc 6578 R Assessee By Shri Manjeet Sachdeva & Avinash Gaur, Ars Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 21.11.2023 Date Of Pronouncement 30.11.2023

Section 142(1)Section 143Section 143(3)Section 263Section 40

…al. Sir, it is not for the department to see how the assessee carries on its business but it is restricted to that the activities are carried on in proper manner. We rely on the following decision J.K. WOOLLEN MANUFACTURERS V. COMMISSIONER OF INCOME TAX, U.P. 72 ITR 612 (SC) Held "In applying the test of commercial expediency for determining whether an expenditure was wholly and exclusively laid out for the assessee's business, purpose of the reasonableness of the expenditure has to be judged from the point of view of the businessman and not of the income-tax department. It is, of course, open to the Appellate Tr…

Giriraj Prasad Goyal, Tonk vs. ITO Tonk, Tonk

In the result, both appeals of the assessee are allowed for statistical

ITA 200/JPR/2023[2014-15]Status: HeardITAT Jaipur05 Jul 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Shrawan Kumar Gupta (Adv.)For Respondent: Smt. Monisha Choudhary (Addl. CIT)

Section 143(3)Section 147Section 148Section 24

…o intervene therein nor he can replace the assessee. Here, whatever decisions were taken by the assessee, has to be understood as taken out of commercial expediency. Kindly refer T.T. Pvt Ltd v/s CIT 121 ITR 551 (Kar), 139 ITR 827 (MP) JK Woolen Manufacturers 72 ITR 612 (SC). 4. Wrong basis at all: It is further submitted that the ld. AO has taken own imaginary basis which is not a good basis looking to the nature of expenses or profession of the assessee and made higher estimated disallowance. The AO has not brought any other single evidence or material on record before making disallowance. Therefore, also the…

Parshavnath Builders, Jaipur vs. PCIT, Udaipur

In the result, the appeal of the assessee is dismissed

ITA 284/JPR/2022[2017-18]Status: DisposedITAT Jaipur20 Jun 2023AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri MahendraGargieya ,Adv. &For Respondent: Shri James Kurian, CIT

Section 143(3)Section 263

…hough they were not required. Law is well settled that business man is the best judge to take care of its interest and the revenue cannot put itself into the shoe of the business man as stated in J.K. Woollen Manufacturers Vs. Commissioner of Income Tax(1969) 72 ITR 612 (SC).It is for the assessee business man, to take a decision who may be required to keep sufficient cash keeping in mind the possible/forthcoming opportunities. 5.1Fairly speaking, from the point of a quasi-judicial authority (the AO), the past history of the case the documents submitted in the response to notices before the Ld. AO, the books of a…

Addl. CIT, Special Range- 1, New Delhi vs. Amway India Enterprises Pvt. Ltd., New Delhi

In the result, the appeal of the revenue is dismissed

ITA 6707/DEL/2018[2012-13]Status: DisposedITAT Delhi08 May 2023AY 2012-13

Bench: Shri C.M. Garg & Dr. B. R. R. Kumaraddl. Cit, Vs. Amway India Enterprises Pvt. Ltd, 1St Floor, Plot No. 8, Elegance Special Range-1, New Delhi Tower, Jasola, New Delhi -110025 (Appellant) (Respondent) Pan: Aaaca5603Q Assessee By : Sh. Sudesh Garg, Adv Sh. Prince Bansal, Ca Ms. Bhavya Garg, Ca Revenue By: Sh. P. Praveen Sidharth, Cit Dr Date Of Hearing 16/02/2023 Date Of Pronouncement 08/05/2023

For Appellant: Sh. Sudesh Garg, AdvFor Respondent: Sh. P. Praveen Sidharth, CIT DR

Section 32Section 37(1)

…the purposes of the business, reasonableness of the expenditure has to be adjudged from the point of view of the businessman and not of the revenue (Jamshedpur Motor Accessories Stores Vs. CIT (1974) 95 ITR 664 (Pat); J.K. Woollen Manufacturers Vs CIT (1969) 72 ITR 612 (SC). In order that an expenditure may be admissible as a deduction under section 10(2)(xv), it is not necessary that the primary motive in incurring it must be directly to earn income thereby (Sree Meenakshi Mills Ltd. Vs. CIT (1967) 63 ITR 207 (SC). In CIT Vs. Malayalam Plantations Ltd. (1960) 53 ITR 140, the Supreme Court has observed at page 1…

Shri Suresh Kumar Goyal, 501 Unique Sanghi Apartment Durgapura Jaipur-302018, Jaipur vs. ACIT Circle-6, Jaipur, Circle-6

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

ITA 664/JPR/2019[2013-14]Status: DisposedITAT Jaipur01 May 2023AY 2013-14

Bench: Hon’ble SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Mahendra Gargieya, Adv. &For Respondent: Mrs. Monisha Choudhary, Addl. CIT

Section 143(3)

…sinessman is the best judge to take care of its own interest & to take decisions in the best of its business interest. Kindly refer T.T. Pvt. Ltd. v/s ITO (1980) 121 ITR 551 (Kar), CIT v/s Udhoji Shrikrishnadas (1983) 139 ITR 827 (MP), JK Woolen Manufacturers 72 ITR 612 (SC). This is evident from the following submissions. 2.2 It needs to be clarified that the services of the agents appointed for ensuring the procurement of the orders with regard to sale, the purpose was not only to get a boost and increase in the sales of the firm but firstly, was to ensure that the existing buyers keep on making purchases from…

ACIT Cir -4(2) (1), Thane vs. M/S. Mukti Gold Pvt. Ltd, Mumbai

Appeal is partly allowed for statistical purpose and the assessee’s C

ITA 1804/MUM/2022[2017-18]Status: DisposedITAT Mumbai17 Feb 2023AY 2017-18

Section 143(3)Section 37(1)Section 68

…nd that none of the decisions have been challenged in this Court. Even otherwise, we are of the view that it is a pure business expense." Further, the Apex Court in the case of CIT v. Walchand & Co. (P.) Ltd. [1967] 65 ITR 381; J.K. Woollen Mfg. v. CIT [1969] 72 ITR 612 (SC) ; Aluminium Corporation of India Ltd. v. CIT [1972] 86 ITR 11 (SC) and S.A. Builders Ltd. v. CIT (Appeals) [2007] 158 Taxman 74/288 ITR 1 (SC) has held that any expenditure incurred out of commercial expediency, the same is an allowable deduction. The commercial expediency is to be considered from the angle of businessman and not from the ang…

Global Consultants & Designers Pvt. Ltd., New Delhi vs. ITO Ward 11(4), New Delhi

The appeal is allowed

ITA 1424/DEL/2019[2015-16]Status: DisposedITAT Delhi25 Jan 2023AY 2015-16

Bench: Sh. Shamim Yahya & Sh. Anubhav Sharmaita No.1424/Del/2019, A.Y. 2015-16

Section 133(6)Section 143(2)Section 143(3)

…e seen from the assessee’s point of view and the Revenue cannot justifiably put itself in the arm-chair of the businessman 9. SA Builders v. CIT : 288 ITR 1 (SC) 10. Hero Cycles Limited v. CIT (SC) : 379 ITR 347 (SC) 11. J.K. Woollen Manufacturers v. CIT : 72 ITR 612 (SC) Re: Tribunal can give finding or direction in relation to other assessment year 12. JCIT v. Mukund Ltd. : 291 ITR 249 (AT) (Mum) 13. Perfect Equipments v. DCIT : 85 ITD 50 (Ahd.) 14. MMTC Limited v. ACIT : ITA No. 5147, 5166/Del/2016 (Del Trib.) ITA No. 1424.Del.2019 M/s. Global Consultants & Designers P. Ltd. 7 7.1. On the other hand,…

DCIT, Central Circle-1, Udipur vs. M/S. Wagad Constrution Company, Udaipur

In the result, appeals of the Revenue are dismissed

ITA 30/JODH/2020[2014-15]Status: DisposedITAT Jodhpur12 Jan 2023AY 2014-15

For Appellant: Shri S.L. Poddar (Advocate)For Respondent: Shri Venkatesh V. (JCIT-Sr.DR)

Section 143(1)

…were not kept properly, still there has to be clear finding that these expenses were not incidental to the business of the assessee or were bogus. This finding is totally lacking in the assessment order. The Hon'ble Supreme Court in the case of J. K. Woollen (72 ITR 612) had observed that the question as to whether an amount claimed as expenditure was laid out or expended wholly or exclusively for the purpose of business, profession or vocation as required under s. 10(2)(xv) of 1922 Act has to be decided on the facts and in the light of the circumstances of each particular case, but the final conclusion on the ad…

Raj Auto Wheels (P) Ltd., Jaipur vs. ACIT, Ajmer

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

ITA 929/JPR/2016[2009-10]Status: DisposedITAT Jaipur09 Nov 2022AY 2009-10

For Appellant: Shri Mahendra Gargieya, AdvocawteFor Respondent: Shri P.R. Meena, C IT-DR

Section 133(6)Section 143(3)Section 145(3)

…sessee. Here, whatever decisions were taken by the assessee, has to be understood as taken out of commercial expediency. Kindly refer T.T. (P) Ltd. v/s CIT (1980) 121 ITR 551 (Kar), CIT v/s Udhoji Shrikrishnadas (1983) 139 ITR 827 (MP) JK Woolen Manufacturers 72 ITR 612 (SC). 1.3 No basis at all: It is further submitted that the ld. AO has not at all provided any basis whatsoever for making the estimated disallowance. 1.4 Reasonable Claim made: It is submitted that looking to a huge turnover of more than Rs.40.48 crores (approx), claim of expenditure is otherwise very meager. Thus such a meager claim to achieve…

M/S. Odisha Power Generation Corporation Limited, Bhubaneswar vs. DCIT, Corporate Circle-1(2), Bhubaneswar

In the result, appeal of the assessee is partly allowed

ITA 131/CTK/2019[2014-15]Status: DisposedITAT Cuttack12 Sept 2022AY 2014-15

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No Ita No.114/Ctk/2014: Assessment Year Assessment Year : 2010-11

For Appellant: S/Shri Dilip Kr. Mohanty/Pradyumna Kumar Sahu

…an and not of the revenue. In support of this contention, he placed reliance upon the judgment of the Supreme Court in CIT v. Walchand & Co. (P.) Ltd. [1967] 65 ITR 381, Eastern Investments Ltd. v. CIT [1951] 20 ITR 1 (SC) and J.K. Woollen Mfrs. v. CIT [1969] 72 ITR 612 (SC). 15. The principle laid down by the Supreme Court in all the three judgments is similar. These judgments state that in applying the test of commercial expediency for determining whether an expenditure was wholly and exclusively laid out for the purpose of the assessee's business, reasonableness of the expenditure has to be judged from the poi…

M/S. Odisha Power Generation Corporation Limited, Bhubaneswar vs. DCIT, Corporate Circle-1(2), Bhubaneswar

In the result, appeal of the assessee is partly allowed

ITA 130/CTK/2019[2013-14]Status: DisposedITAT Cuttack12 Sept 2022AY 2013-14

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No Ita No.114/Ctk/2014: Assessment Year Assessment Year : 2010-11

For Appellant: S/Shri Dilip Kr. Mohanty/Pradyumna Kumar Sahu