How many judgments cite Kedarnath Jute Mfg. Co. Ltd. v. CIT?

654 judgments on BharatTax cite Kedarnath Jute Mfg. Co. Ltd. v. CIT (82 ITR 363), spanning 1998 to 2026.

Which sections of the Income Tax Act does Kedarnath Jute Mfg. Co. Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 1961, Section 37(1), Section 43B, Section 14A, Section 115JB.

Kedarnath Jute Mfg. Co. Ltd. v. CIT

82 ITR 363Supreme Court of India1971#89 most cited

What is Kedarnath Jute Mfg. Co. Ltd. v. CIT authority for?

Tax liability for an item of income or expenditure is determined solely by the provisions of the Income-tax Act. Entries in an assessee's books of account are not conclusive and do not govern the taxability or deductibility of an item, as the legal rights and obligations under the Act prevail.

654

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 1998 to 2026.

Also referred to as

Kedarnath Jute Mfg. Co. Ltd. v. CIT · 82 ITR 363 SC · tax liability · accounting entries · books of account · Income-tax Act provisions · tax law vs accounting · section 145 · mercantile system · book profits · section 115JB · section 37(1) · section 43B

Sections most often in play

Section 143(3)Section 1961 Section 37(1)Section 43B Section 14A Section 115JB Section 143(1)Section 145

Read the full judgment

Issues it is cited on

section 80hhc section 80hh book profits revenue expenditure section 80ia mercantile system of accounting capital expenditure section 115j section 80i disallowance under section 14a section 37(1)section 115jb

Judgments citing Kedarnath Jute Mfg. Co. Ltd. v. CIT

Commissoner of Income Tax vs. M/S Shaw Wallace

In the result, the appeal fails and is hereby

ITA/501/2013HC Karnataka09 Nov 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 143(3)Section 14ASection 260Section 41(1)

…Tribunal thereupon has recorded the finding that the expenses were incurred during the relevant Assessment Year and therefore, the claim was allowable, by placing reliance on the decision of Supreme Court in 'KEDARNATH JUTE MFG. COMPANY LIMITED Vs. CIT' 82 ITR 363 (SC). The aforesaid finding is a finding of fact which is based on meticulous appreciation of evidence on record. The Tribunal, by placing reliance on the decision of the Supreme Court in BHARAT 13 EARTH MOVERS, supra, has held that a business liability should arise in the accounting year and it should be capable of estimated with reaso…

Sarita Dudheria, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result appeal filed by assessee stands partly allowed

ITA 723/BANG/2016[2010-11]Status: DisposedITAT Bangalore06 Nov 2020AY 2010-11

Bench: Shri A. K. Garodia & Smt. Beena Pillaiassessment Years : 2010 – 11

For Appellant: Shri.KR.Pradeep CA along with Smt.Girija G.P.CAFor Respondent: Shri.Priyadarshi Mishra

Section 131Section 132Section 132(4)Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 234A

…ed that if any proceedings could be initiated shall be only under section 153C read with 153A of the Act, in the case of assessee. He placed reliance on following decisions in support of his contention: • Kedarnath Jute Manufacturing Co Ltd vs CIT reported in 82 ITR 363 (SC) • Tansukhari Bodulal vs ITU and Ors. Reported in 46 ITR 325 (FB- Assam) • Manvy Bros vs CIT reported in Bom HC 93 CCH 40 • Smt. Bhagya Nagaraj vs DCIT in ITA No.93-96/Bang/2017 for assessment year 2005-06 to 2008-09 by order dated 25/10/2017 • ACIT vs Sh.Srinivas Rao Hoskote in ITA No.1154-1155/Bang/2015 for assessment years 2010-11 and 2011-…

Bnp Paribas India Holding P. Ltd., Mumbai vs. ACIT -14(1)(1), Mumbai

ITA 1496/MUM/2020[2017-78]Status: DisposedITAT Mumbai12 Oct 2020AY 2017-78

Bench: Shri Pramod Kumar & Shri Ravish Sood

For Appellant: Shri Farrokh V. Irani , ARFor Respondent: Shri Rahul Raman, CIT-DR

Section 143(1)Section 143(1)(a)Section 143(3)Section 156Section 234BSection 234C

…the said Act. It is also significant to note that the assessee's entitlement to claim deduction had been held to be valid in view of an earlier judgment of the Supreme Court in Kedarnath Jute Manufacturing Company Limited v. Commissioner of Income-tax, (1971) 82 ITR 363. This BNP Paribas India Holding P. Ltd. Vs. ACIT- 14(1)(1), Mumbai. 12 A.Y 2017-18 – ITA No. 1496/Mum/2020 was, therefore, a case of error in perception/judgment. Despite the same, the Supreme Court upheld the decision of the Appellate Assistant Commissioner in allowing the deduction. The words "could not have been raised" must, therefore, be cons…

Shri Nitin Sharma, Jabalpur vs. Principal Commissioner of Income Tax -2, Jabalpur

In the result, the appeal is partly allowed

ITA 25/JAB/2019[2014-15]Status: DisposedITAT Jabalpur28 Sept 2020AY 2014-15

Bench: Shri N.R.S. Ganesan & Shri Sanjay Arora

Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153A(1)Section 153CSection 153C(1)Section 153DSection 263Section 7(1)

…which though nothing turns on. It is the correct legal position that is relevant, and not the view that the parties may take of their rights in the matter (CIT v. C. Parakh & Co. (India) Ltd. [1956] 29 ITR 661 (SC); Kedarnath Jute Mfg. Co. Ltd. v. CIT [1971] 82 ITR 363 (SC)). A ‘mistake’, in any case, cannot give rise to any right to the other side. Any surviving doubt in the matter would stand quenched with reference to s. 292B. 4.2 Continuing further, as we see it, the assessment in the instant case is a regular assessment u/s. 143(3) of the Act, made upon service of a notice u/s. 143(2) dated 20/09/2016 on 23…

ACIT 4(3)(1), Mumbai vs. The New Piece Goods Bazar Co. Ltd, Mumbai

In the result, the Revenues’s appeal is partly allowed for statistical purposes

ITA 6496/MUM/2017[2014-15]Status: DisposedITAT Mumbai25 Sept 2020AY 2014-15

For Appellant: Ms. Kavita P. Kaushik (DR)For Respondent: Sh. B.V. Jhaveri (Adv.)

Section 143(3)Section 22Section 24

…estopple against law. Further, it is not the view that the parties may take of their rights in the matter, but the correct legal position, that is relevant (CIT v. C. Parak & Co. (India) Ltd. [1956] 29 ITR 661 (SC); Kedernath Jute Mfg. Co. Ltd. v. CIT [1971] 82 ITR 363 (SC)). We have in fact observed that the expenditure on watchman salary has no bearing on the rental income, or its earning, so that it cannot even otherwise be regarded as contemplated u/s. 23, or u/s. 24(a), qua which a gross (lumpsum) allowance is now provided at a fixed rate (sum). In other words, the notion of the assessee obtaining any ‘bene…

M/S Mrinalini Biri Manufacturing Co., Kolkata vs. D.C.I.T., Circle-8(1), Kolkata

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

ITA 85/KOL/2020[2012-13]Status: DisposedITAT Kolkata16 Sept 2020AY 2012-13

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.85/Kol/2020 ("नधा"रणवष" / Assessment Year:2012-13)

For Appellant: Shri A. K. Tulsiyan, FCAFor Respondent: Shri Dhrubajyoti Roy, JCIT

Section 143(3)Section 36(1)(v)Section 37(1)Section 40

…pt of provision applied not only in respect of companies but also to individual assessees. M/s Mrinalini Biri Manufacturing Co Assessment Year:2012-13 18. Reliance was also placed on the observations of this Court in Kedarnath Jute Mfg. Co. Ltd. v. CIT [1971] 82 ITR 363 where it was emphasised that whether an assessee was entitled to a particular deduction or not depended on the provision of law relating thereto and not on the view that the assessee might take of his rights; nor could the existence or absence of entries in the books of account be decisive or conclusive in the matter. The assessee who was maintain…

Mannulal Jagannath Das Trust Hospital, Jabalpur vs. Commissioner of Income Tax (E), Bhopal

In the result, the appeal is allowed for statistical purposes

ITA 13/JAB/2019[2018-19]Status: DisposedITAT Jabalpur07 Sept 2020AY 2018-19

Bench: S/Shri Nrs Ganesan & Sanjay Arora

Section 10Section 10(1)Section 11Section 12ASection 80GSection 80G(5)Section 80G(5)(vi)

…pel against law. Though, in law, it is not the view that the parties may take of their rights in the matter, but the correct legal position that is relevant (CIT v. C. Parak & Co. (India) Ltd. [1956] 29 ITR 661 (SC); Kedernath Jute Mfg. Co. Ltd. v. CIT [1971] 82 ITR 363 (SC)), there is, we find, no clear finding in the absence of examination of facts by the competent authority in the instant case. We are not, we may at the cost of repetition state, expressing any opinion except to, on being called upon to, state the position of law which endorses our decision to, on finding the facts indeterminate, require examin…

Jsm Corporation P. Ltd, Mumbai vs. Asst CIT 6(3), Mumbai

In the result, the appeal filed by the assessee is hereby ordered to be allowed for statistical purposes

ITA 3236/MUM/2015[2010-11]Status: DisposedITAT Mumbai07 Aug 2020AY 2010-11

Bench: Shri Pramod Kumar, Vp & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No. 3236/Mum/2015 (निर्धारण वर्ा / Assessment Year: 2010-11) M/S. Jsm Corporation Pvt. बिधम/ Acit-6(3) Ltd. Mumbai. Vs. Todi Estate, A Wing, 3Rd Floor, Sunmill Compound, Sitaram Jadhav Marg, Lower Parel, Mumbai-400013. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabch5026K (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Ms. Pramita Rathi/ Ishwer P. Rathi Revenue By: Shri Padma Ram (Sr. Dr) सुनवाई की तारीख / Date Of Hearing: 05/02/2020 घोषणा की तारीख /Date Of Pronouncement: 07/08/2020 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Order Dated 10.03.2015 Passed By The Commissioner Of Income Tax (Appeals)-15, Mumbai [Hereinafter Referred To As The “Cit(A)”] Relevant To The A.Y. 2010-11. The Assessee Has Raised The Following Grounds: - 2. “1. The Learned Cit(A) Erred In Confirming The Disallowance Of The Revenue Expenses Of Rs.1,92,30,263/- Only Oil Ground That The Assessee Has Shown The Expenses Under The Head Preoperative Expenses In The Books Of Account.

For Appellant: Ms. Pramita Rathi/ Ishwer P. RathiFor Respondent: Shri Padma Ram (Sr. DR)

Section 143(1)Section 143(2)Section 234A

…nt are concerned, it is well-settled that they do not clinch the issue either way, and they do not determine the allowability or otherwise of the expenditure. The decisions of the Hon'ble Supreme Court in the case of Kedarnath Jute Mfg. Co. Ltd. v. CIT [1971] 82 ITR 363 (SC) and in the case of CIT v. India Discount Co. Ltd. [1970] 75 ITA. No3236/M/2015 A.Y. 2010-11 ITR 191 (SC) are clear on the issue. If the argument of the learned Departmental Representative that the entries in the books of account are sacroscent and have to be accepted is to be valid, then in the case of depreciation also, the claim of the as…

Gujarat Mineral Development Corporation Ltd., Ahmedabad vs. The ACIT, Circle-2(1)(1), Ahmedabad

In the result, both appeals filed by the assessee are allowed for statistical purposes

ITA 2278/AHD/2018[2015-16]Status: DisposedITAT Ahmedabad28 Jul 2020AY 2015-16

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri S. N. Soparkar, Sr. Advocate & Shri ParinFor Respondent: Shri Vinod Tanwani, Sr.D.R

Section 143(3)Section 14A

…duction. It has been held repeatedly by this Court that entries in the books of account are not determinative or conclusive and the matter is to be examined on the touchstone of provisions contained in the Act [See – Kedarnath Jute Mfg. Co. Ltd. v. CIT [1971] 82 ITR 363 (SC); Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT [1997] 227 ITR 172/93 Taxman 502 (SC); Sutlej Cotton Mills Ltd. v. CIT [1979] 116 ITR 1 (SC) and United Commercial Bank v. CIT [1992] 240 ITR 355/106 Taxman 601 (SC). 20. At the most, an inference can be drawn that by showing this expenditure in a spread over manner in the books of account…

Gujarat Mineral Development Corporation Ltd., Ahmedabad vs. The ACIT, Circle-2(1)(1), Ahmedabad

In the result, both appeals filed by the assessee are allowed for statistical purposes

ITA 2277/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad28 Jul 2020AY 2014-15

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri S. N. Soparkar, Sr. Advocate & Shri ParinFor Respondent: Shri Vinod Tanwani, Sr.D.R

Section 143(3)Section 14A

Futura Polysters Ltd, Mumbai vs. Income Tax Officer 6(3)(1), Mumbai

ITA 1460/MUM/2018[2013-14]Status: DisposedITAT Mumbai16 Jul 2020AY 2013-14

Bench: Shri Pramod Kumar & Shri Ravish Soodita Nos.1459-1460/Mum/2018 (Assessment Year: 2013-14) Futura Polyster Limited Ito 6(3)(1) B-22, T.V. Indl Estate, Aayakar Bhavan, Vs. S.K. Ahire Marg, Worli, M.K. Road, Churchgate, Mumbai – 400 030 Mumbai – 400 020 Pan – Aaaci3404K (Appellant) (Respondent) Appellant By: Shri Vijay Mehta & Shri Anuj Kisnadwala, A.R‘S Respondent By: Shri Debashis Chanda, D.R Date Of Hearing: 15.01.2020 Date Of Pronouncement: 16.07.2020

For Appellant: Shri Vijay Mehta &For Respondent: Shri Debashis Chanda, D.R

Section 143(3)Section 154Section 41(1)(a)Section 43BSection 68

…the said Act. It is also significant to note that the assessee's entitlement to claim deduction had been held to be valid in view of an earlier judgment of the Supreme Court in Kedarnath Jute Manufacturing Company Limited v. Commissioner of Income-tax, (1971) 82 ITR 363. This was, therefore, a case of error in perception/judgment. Despite the same, the Supreme Court upheld the decision of the Appellate Assistant Commissioner in allowing the deduction. The words "could not have been raised" must, therefore, be construed liberally and not strictly. 15. It is indeed a question of exercise of discretion whether or no…

Futura Polysters Ltd, Mumbai vs. Income Tax Officer 6(3)(1), Mumbai

ITA 1459/MUM/2018[2013-14]Status: DisposedITAT Mumbai16 Jul 2020AY 2013-14

For Appellant: Shri Vijay Mehta &For Respondent: Shri Debashis Chanda, D.R

Section 143(3)Section 154Section 41(1)(a)Section 43BSection 68

…the said Act. It is also significant to note that the assessee's entitlement to claim deduction had been held to be valid in view of an earlier judgment of the Supreme Court in Kedarnath Jute Manufacturing Company Limited v. Commissioner of Income-tax, (1971) 82 ITR 363. This was, therefore, a case of error in perception/judgment. Despite the same, the Supreme Court upheld the decision of the Appellate Assistant Commissioner in allowing the deduction. The words "could not have been raised" must, therefore, be construed liberally and not strictly. 15. It is indeed a question of exercise of discretion whether or no…

The ACIT, Cochin vs. M/S.Ptl Enterprises Ltd, Cochin

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

ITA 84/COCH/2020[2014-15]Status: DisposedITAT Cochin06 Jul 2020AY 2014-15

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Mritunjaya Sharma, CIT-DRFor Respondent: S/Sri.Joseph Marcose, Sr.Advocate &

Section 56(2)(ii)

…It is well settled principle that treatment in books of accounts is not determinative of the nature and taxability of income as held in the case of Tuticorin alkali Chemicals and Fertilizers Ltd. v. CIT 227 ITR 172 (SC) and Kedarnath Jute Mfg. Co. Ltd. v CIT 82 ITR 363 (SC). 8.27 For the sake of completeness, it is stated that it is well settled law that if there is a new ground or a material change in the factual and legal position precedents do not have binding character. In the case of Bharat Sanchar Nigam Ltd. v UOI WP (Civil) 183/2003 (SC), it was noted as under: “Even if the said orders are passed under…

ACIT, Circle- 2(2), New Delhi vs. Anant Raj Ltd., New Delhi

In the result assessee’s appeal is partly allowed and Revenue’s appeal is dismissed

ITA 5677/DEL/2017[2013-14]Status: DisposedITAT Delhi11 May 2020AY 2013-14

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

For Appellant: Shri V.K. Bindal, CAFor Respondent: Shri Sanjay Goel, CIT-DR

Section 143(3)Section 36(1)(vii)Section 36(2)Section 4Section 50C

…the following judgments: (a) S.S. Gadgil Vs Lal and Co. 53 ITR 231(SC) (b) CIT v. Shelly Products [2003] 261 ITR 367 (SC) (c) Vijay Gupta [2016] 68 taxmann.com 131 (Delhi) (d) Abdul Qayume Vs CIT (1990) 184 ITR 404 (All) (e) Kedarnath Jute Mfg. Co. Ltd.Vs CIT 82 ITR 363 (SC) (f) CIT Vs Bharat General Reinsurance Co. Limited. 81 ITR 303 (Delhi) (g) R. Seshammal vs ITO 237 ITR 185 (Madras) (h) CIT Vs Bhawani Singhji [2018] 99 taxmann.com 338 (Delhi) (i) Shri Vipul P. Dalal Vs. DCIT - 12(2) 2016-LL-0603-1]- ITAT Mumbai (j) DCIT vs. Lab India Instruments (P) Ltd., 93 ITD 120 / 2005- TIOL-49-ITAT-PUNE (k) Raghavan Nai…

Anant Raj Ltd, New Delhi vs. Addl.CIT, Range-2, Circle-2(2), New Delhi

In the result assessee’s appeal is partly allowed and Revenue’s appeal is dismissed

ITA 5169/DEL/2017[2013-14]Status: DisposedITAT Delhi11 May 2020AY 2013-14

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

For Appellant: Shri V.K. Bindal, CAFor Respondent: Shri Sanjay Goel, CIT-DR

Section 143(3)Section 36(1)(vii)Section 36(2)Section 4Section 50C

Pinakin Laxmichand Shah, Mumbai vs. ACIT - 19 (2), Mumbai

In the result, assessee’s appeals are partly allowed for statistical purposes

ITA 6112/MUM/2018[2013-14]Status: DisposedITAT Mumbai13 Mar 2020AY 2013-14

Bench: Shri Saktijit Dey & Shri S. Rifaur Rahman

For Appellant: Shri S.C. Tiwari a/wFor Respondent: Shri Kumar Padmapani Bora

Section 36Section 57

…sessing Officer and the first appellate authority respectively. Further, in support of his contention, the learned Authorised Representative relied upon the following decisions:– 5 Shri Pinakin Laxmichand Shah i) Kedarnath Jute Mfg. Co. Ltd. v/s CIT, [1971] 82 ITR 363 (SC); ii) Jute Corporation of India Ltd. v/s CIT, [1990] 53 Taxman 85 (SC); iii) CIT v/s Nirbheram Deluram, [1997] 91 Taxman 181 (SC); iv) National Thermal Power Co. Ltd. v/s CIT, [1998] 229 ITR 383 (SC); v) Woolcombers of India Ltd. v/s CIT, [1981] 7 Taxman 188 (Cal.); vi) East India Pharmaceutical Works Ltd. v/s CIT, [1997] 91 Taxman 185 (SC); a…

Salzer Electronics Limited, Chennai vs. ITO, Corporate Ward - 4, Coimbatore

In the result, the appeal filed by the assessee in ITA

ITA 1858/CHNY/2019[2016-17]Status: DisposedITAT Chennai26 Feb 2020AY 2016-17

Bench: Shri George Mathan & Shri Inturi Rama Rao

For Appellant: Shri. S.Sridhar, AdvocateFor Respondent: Shri. D. Manoj Kumar, CIT

Section 143(3)Section 14A

…e and presence of entry in the books of accounts does not decide the allowability or otherwise of an item of expenditure, reliance in this regard can be placed on the judgment of Hon’ble Supreme Court in the case of Kedamath Jute Mills :- 7 -: Co. Ltd (1971) 82 ITR 363. It is further worth to note that SEBI had repealed the ESOP expenditure, once provision is repealed it should be deemed that it was never part of guideline note. Accordingly, the orders of the Assessing Officer and ld. Commissioner of Income Tax (Appeals) are set aside and we direct the Assessing Officer to allow the claim of deduction of ESOP…

Deputy Commissioner of Income Tax Central Circle-1(3), Bangalore vs. M/S Coffeeday Global Limited, Bangalore

In the result, the appeals of the Revenue are partly allowed

ITA 3041/BANG/2018[2014-15]Status: DisposedITAT Bangalore24 Feb 2020AY 2014-15

Bench: S/Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm Ita Nos. 3040 & 3041/Bang/2018 Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Coffee Day Global Limited, Income-Tax, Central Circle-1(3), No.23/2, Coffeeday Square, 3Rd Floor, C.R. Building, Vittal Mallya Road, Queen’S Road, Bengaluru-560 001. Bengaluru-560 001. [Pan: Aabca 5291P]

Section 14ASection 32(1)(iia)Section 43A

…xpenditure is as per the provisions of the Act and the treatment of such expenditure in the books of accounts is immaterial. There by the Supreme court has again confirmed its own decision in the case of M/s.Kedarnath Jute Manufacturing Co., Ltd V. CIT (1971) 82 ITR 363 (SC). It is therefore a decided position of law that, merely because a different treatment was given to an expenditure in the books, the assessee cannot be denied of such expenditure while computing the total income as per the provisions of the Act, if such expenditure is otherwise allowable as per the said provisions. 10.7 The Ld. AR also relied…

Deputy Commissioner of Income Tax Central Circle-1(3), Bangalore vs. M/S Coffeeday Global Limited, Bangalore

In the result, the appeals of the Revenue are partly allowed

ITA 3040/BANG/2018[2013-14]Status: DisposedITAT Bangalore24 Feb 2020AY 2013-14

Section 14ASection 32(1)(iia)Section 43A

DCIT, Gurgaon vs. M/S. Plant Edu. (P) Ltd., Gurgaon

ITA 3702/DEL/2015[2009-10]Status: DisposedITAT Delhi31 Jan 2020AY 2009-10

Bench: Shri Kuldip Singh & Dr. B.R.R. Kumar

For Appellant: Shri Sanjay Sood, CAFor Respondent: Shri Saras Kumar, Senior DR

Section 145(3)Section 40A(2)(b)

…ed these expenditure incurred on Project EDEXCEL and held the same of revenue in nature following the decisions of the Hon’ble Supreme Court in cases of Kedarnath 15 ITA Nos.3472 & 3473/Del./2015 ITA Nos.3702 & 3574/Del./2015 Jute Manufacturing Co. vs. CIT 82 ITR 363 and CIT vs. Indian Discounts Co. Ltd. 75 ITR 91. Order passed by the ld. CIT (A) was challenged by the Revenue before the Tribunal who has remanded the matter back to AO and AO vide assessment order dated 11.05.2016, available at pages 57 to 59 of the paper book, accepted the claim of the assessee qua Project EDEXCEL expenses, thus the issue…