Jamshedpur Motor Accessories Stores v. CIT

95 ITR 664High Court1974#4301 most cited

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

For expenditure to be deductible, its reasonableness must be judged from the businessman's perspective, not the revenue's, considering commercial expediency.

28

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2023.

Also referred to as

Jamshedpur Motor Accessories Stores v CIT · 95 ITR 664 · business expenditure · commercial expediency · reasonableness of expenditure · businessman's point of view · section 10(2)(xv)

Judgments citing Jamshedpur Motor Accessories Stores v. CIT

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)

…her the expenditure was wholly and exclusively laid out for 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.…

HIGHGRACE INVESTMENTS P. LTD., HYD,HYDERABAD vs. ACIT, CENTRAL CIRCLE-8, HYD, HYDERABAD

Appeals are allowed in above terms

ITA 635/HYD/2015[2008-09]Status: DisposedITAT Hyderabad13 Apr 2022AY 2008-09

Bench: Shri S.S. Godara & Shri L. P. Sahu

For Respondent: Shri T. Sunil Goutam. (D.R.)
Section 143(3)Section 37(1)Section 40A(2)(a)

…her the expenditure was wholly and exclusively laid out for 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1. T…

HIGHGRACE INVESTMENTS P. LTD., HYD,HYDERABAD vs. ACIT, CENTRAL CIRCLE-8, HYD, HYDERABAD

Appeals are allowed in above terms

ITA 634/HYD/2015[2007-08]Status: DisposedITAT Hyderabad13 Apr 2022AY 2007-08

Bench: Shri S.S. Godara & Shri L. P. Sahu

For Respondent: Shri T. Sunil Goutam. (D.R.)
Section 143(3)Section 37(1)Section 40A(2)(a)

…her the expenditure was wholly and exclusively laid out for 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1. T…

ELEM INVESTMENTS P. LTD., HYD,HYDERABAD vs. ACIT, CENTRAL CIRCLE-8, HYD, HYDERABAD

Appeals are allowed in above terms

ITA 624/HYD/2015[2007-08]Status: DisposedITAT Hyderabad13 Apr 2022AY 2007-08

Bench: Shri S.S. Godara & Shri L. P. Sahu

For Respondent: Shri T. Sunil Goutam. (D.R.)
Section 143(3)Section 37(1)Section 40A(2)(a)

…her the expenditure was wholly and exclusively laid out for 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1. T…

RAKESH VAID,NEW DELHI vs. ITO WARD - 62(2), NEW DELHI

In the result, assessee’s appeal, ITA no

ITA 7821/DEL/2019[2010-11]Status: DisposedITAT Delhi08 Apr 2022AY 2010-11

Bench: Shri Kul Bharat[Assessment Year: 2010-11]

Section 145(3)Section 147Section 148Section 151

…and nature of payment in workers, muster roll etc. question and not the method of the payment or its measure, that should be the basis of determining the taxability of an item under the provisions of the Act, Reliance is placed on the following decisions: (i) 95 ITR 664 Jamshedpur Motor Accessories Stores vs. CIT Bihar & Orissa (ii) (3 ITC 219) Indian Turpentine & Rosin co Ltd. Vs. CIT United Provinces. (iii) 42 ITR 392 (SC) Senariram Doongarmal vs. CIT (iv) 74 ITR 7 (SC) New Savan Sugar & Gur Refining Co. Ltd. 2 Finding of AO in remand proceeding Issue: Purchase invoices - That during the course of remand In th…

ITO, WARD - 2(3), KOLKATA, KOLKATA vs. M/S. HEIGHT INSURANCE SERVICES LTD.,, KOLKATA

In the result, the appeal of the revenue is dismissed

ITA 2163/KOL/2017[2009-10]Status: DisposedITAT Kolkata22 Jan 2020AY 2009-10

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.2163/Kol/2017 ("नधा"रणवष" / Assessment Year: 2009-10)

For Appellant: Shri Radhey Shyam, CITFor Respondent: Shri A.K. Tibrewal, FCA
Section 133Section 143(3)

…her the expenditure was wholly and exclusively laid out for 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. Woolllen Manufacturers Vs CIT (1969) 72 ITR 612 ((SC). In order for an expenditure to be admissible as a deduction under section 10(2) (xv), it is not necessary that the primary motive in incurring it has to be directly to earn income thereby (Sree Meenakshi Mills Ltd. Vs. CIT (1967) 63 ITR 207 (SC). The Supreme Court in CIT Vs. Kalyay…

M/S ELEM INVESTMENT(P)LIMITED,HYDERABAD vs. THE DICT, HYDERABAD

In the result, appeal of assessee for AY

ITA 121/HYD/2010[2005-06]Status: DisposedITAT Hyderabad03 Aug 2018AY 2005-06

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahappellant Respondent

For Appellant: Shri K.C. Devdas, ARFor Respondent: Smt. Suman Malik, DR
Section 37(1)Section 40A(2)

…ely laid out for the :- 14 -: M/s. Elem Investments Pvt. Ltd., 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1.…

M/S FINCITY INVESTMENTS PVT LTD,HYDERABAD vs. DCIT, HYDERABAD

In the result, appeal of assessee for AY

ITA 119/HYD/2010[2005-06]Status: DisposedITAT Hyderabad03 Aug 2018AY 2005-06

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri K.C. Devdas, ARFor Respondent: Smt. Suman Malik, DR
Section 37(1)Section 40A(2)

…her the expenditure was wholly and exclusively laid out for 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1.…

M/S HIGHGRACE INVESTMENTS PVT LTD,HYDERABAD vs. DCIT, HYDERABAD

In the result, appeal of assessee for AY

ITA 114/HYD/2010[2005-06]Status: DisposedITAT Hyderabad03 Aug 2018AY 2005-06

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahappellant Respondent

For Appellant: Shri K.C. Devdas, ARFor Respondent: Smt. Suman Malik, DR
Section 37(1)Section 40A(2)

…aid out for the :- 14 -: M/s. Highgrace Investments Pvt. Ltd., 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1.…

M/S FINCITY INVESTMENTS PVT.LTD.,,HYDERABAD vs. ACIT, HYDERABAD

In the result, appeal of assessee for AY

ITA 591/HYD/2006[2002-03]Status: DisposedITAT Hyderabad03 Aug 2018AY 2002-03

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri K.C. Devdas, ARFor Respondent: Smt. Suman Malik, DR
Section 37(1)Section 40A(2)

…her the expenditure was wholly and exclusively laid out for 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1.…

M/S HIGHGRACE INVESTEMENTS PVT.LTD.,,HYDERABAD vs. ACIT, HYDERABAD

In the result, appeal of assessee for AY

ITA 590/HYD/2006[2002-03]Status: DisposedITAT Hyderabad03 Aug 2018AY 2002-03

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahappellant Respondent

For Appellant: Shri K.C. Devdas, ARFor Respondent: Smt. Suman Malik, DR
Section 37(1)Section 40A(2)

…aid out for the :- 14 -: M/s. Highgrace Investments Pvt. Ltd., 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1.…

M/S ELEM INVESTMENTS PVT.LTD.,,HYDERABAD vs. ACIT, HYDERABAD

In the result, appeal of assessee for AY

ITA 589/HYD/2006[2002-03]Status: DisposedITAT Hyderabad03 Aug 2018AY 2002-03

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahappellant Respondent

For Appellant: Shri K.C. Devdas, ARFor Respondent: Smt. Suman Malik, DR
Section 37(1)Section 40A(2)

…ely laid out for the :- 14 -: M/s. Elem Investments Pvt. Ltd., 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1.…

M/S VECYES INVESTEMENT PVT LTD.,,HYDERABAD vs. ACIT, HYDERABAD

In the result, the appeal of assessee is partly allowed

ITA 588/HYD/2006[2002-03]Status: DisposedITAT Hyderabad03 Aug 2018AY 2002-03

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri K.C. Devdas, ARFor Respondent: Smt. Suman Malik, DR
Section 37(1)Section 40A(2)

…her the expenditure was wholly and exclusively laid out for 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. :- 14…

M/S HIGH GRACE INVESTMENTS PVT.LTD.,,HYDERABAD vs. ACIT, HYDERABAD

In the result, appeal of assessee for AY

ITA 619/HYD/2008[2004-05]Status: DisposedITAT Hyderabad03 Aug 2018AY 2004-05

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahappellant Respondent

For Appellant: Shri K.C. Devdas, ARFor Respondent: Smt. Suman Malik, DR
Section 37(1)Section 40A(2)

…aid out for the :- 14 -: M/s. Highgrace Investments Pvt. Ltd., 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1.…

M/S ELEM INVESTMENTS PVT.LTD.,,HYDERABAD vs. ACIT, HYDERABAD

In the result, appeal of assessee for AY

ITA 617/HYD/2008[2004-05]Status: DisposedITAT Hyderabad03 Aug 2018AY 2004-05

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahappellant Respondent

For Appellant: Shri K.C. Devdas, ARFor Respondent: Smt. Suman Malik, DR
Section 37(1)Section 40A(2)

…ely laid out for the :- 14 -: M/s. Elem Investments Pvt. Ltd., 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1.…

M/S FINCITY INVESTMENTS PVT.LTD.,,HYDERABAD vs. ACIT, HYDERABAD

In the result, appeal of assessee for AY

ITA 616/HYD/2008[2004-05]Status: DisposedITAT Hyderabad03 Aug 2018AY 2004-05

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri K.C. Devdas, ARFor Respondent: Smt. Suman Malik, DR
Section 37(1)Section 40A(2)

…her the expenditure was wholly and exclusively laid out for 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1.…

M/S HIGHGRACE INVESTEMENTS PVT.LTD.,,HYDERABAD vs. ACIT, HYDERABAD

In the result, appeal of assessee for AY

ITA 733/HYD/2006[2003-04]Status: DisposedITAT Hyderabad03 Aug 2018AY 2003-04

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahappellant Respondent

For Appellant: Shri K.C. Devdas, ARFor Respondent: Smt. Suman Malik, DR
Section 37(1)Section 40A(2)

…aid out for the :- 14 -: M/s. Highgrace Investments Pvt. Ltd., 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1.…

M/S FINCITY INVESTMENTS PVT.LTD.,,HYDERABAD vs. ACIT, HYDERABAD

In the result, appeal of assessee for AY

ITA 732/HYD/2006[2003-04]Status: DisposedITAT Hyderabad03 Aug 2018AY 2003-04

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri K.C. Devdas, ARFor Respondent: Smt. Suman Malik, DR
Section 37(1)Section 40A(2)

…her the expenditure was wholly and exclusively laid out for 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1.…

M/S ELEM INVESTMENTS PVT.LTD.,,HYDERABAD vs. ACIT, HYDERABAD

In the result, appeal of assessee for AY

ITA 731/HYD/2006[2003-04]Status: DisposedITAT Hyderabad03 Aug 2018AY 2003-04

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahappellant Respondent

For Appellant: Shri K.C. Devdas, ARFor Respondent: Smt. Suman Malik, DR
Section 37(1)Section 40A(2)

…ely laid out for the :- 14 -: M/s. Elem Investments Pvt. Ltd., 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 CIT Vs. Chandulal Keshavlal & Co. (1960) 38 ITR 601 (SC), it was held by the SC that in deciding whether a payment of money is a deductible expenditure, one has to take into consideration questions of commercial expediency and the principles of ordinary commercial trading. 10.1.…

ITO, WARD-2(3), DURGAPUR, KOLKATA vs. M/S HEIGHT INSURANCE SERVICES LTD., KOLKATA

Appeal is dismissed

ITA 2266/KOL/2016[2011-12]Status: DisposedITAT Kolkata08 Jun 2018AY 2011-12

Bench: Shri S.S.Godara & Dr. A.L. Sainiassessment Year :2011-12 Income Tax Officer, V/S. M/S Height Insurance Ward-2(3), R/No.10/21, Services Ltd., Room 7Th Floor, Aayakar No.319,3Rd Floor, Bhawan, P-7, Kamalaya Centre, 156A, Chowringhee Square, Lenin Sarani, Kolakta-13 Kolkata-69 [Pan No.Aacch 0943 G] .. अपीलाथ" /Appellant ""यथ"/Respondent Md. Usman, Cit-Dr अपीलाथ" क" ओर से/By Appellant Shri A.K. Tibrewal, Fca ""यथ" क" ओर से/By Respondent 31-05-2018 सुनवाई क" तार"ख/Date Of Hearing 08-06-2018 घोषणा क" तार"ख/Date Of Pronouncement आदेश /O R D E R Per S.S.Godara:- This Revenue’S Appeal For Assessment Year 2011-12 Arises Against Commissioner Of Income Tax (Appeals)-14, Kolkata’S Order Dated 31.08.2016 In Case No. 188/Cit(A)-14/Wd-1(1)/2015-16, In Proceedings U/S 143(3) Of The Income Tax Act, 1961; In Short ‘The Act’. 2. The Revenue’S Solitary Grievance Pleaded In The Instant Appeal Seeks To Revive Section 37 R.W 40(A)(Ia) Disallowances / Addition Of ₹66,18,00,000/- Pertaining To Assessee’S Service Charges Paid To M/S Golden Trust Financial Services (Gtfs) Hereafter For Having Acted As Its Agent. It’S Next Two Averments Are That The Cit(A) Has Erred In Law As Well As On Facts In Examining Assessee’S Exclusive Method Of Accounting In Service Tax Receivable On Output Services As Against Inclusive Method Of Service Tax

Section 143(3)Section 37

…her the expenditure was wholly and exclusively laid out for 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. Woolllen Manufacturers Vs CIT (1969) 72 ITR 612 ((SC). In order for an expenditure to be admissible as a deduction under section 10(2) (xv), it is not necessary that the primary motive in incurring it has to be directly to earn income thereby (Sree Meenakshi Mills Ltd. Vs. CIT (1967) 63 ITR 207 (SC). ITA No.2266/Kol/2016 A.Y.2011-12 I…

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