Ltd. v. DCIT

22 SOT 7Income Tax Appellate Tribunal2008#848 most cited

What is Ltd. v. DCIT authority for?

An adverse inference cannot be drawn against an assessee based on a document found with a third party during a search, as possession is only attributable to the searched person. An addition to income based solely on an undated, unsigned seized document, without further corroborative evidence or inquiry, is not sustainable.

123

judgments rely on this decision, according to BharatTax’s citation analysis of 366,459 Indian tax judgments — from 2010 to 2025.

Also referred to as

SMC Share Brokers Ltd. v. DCIT · Section 153C · Section 132 · Section 69 · document seized · third party possession · adverse inference · undated unsigned document · unexplained investment · block assessment · incriminating evidence

Also reported as

102 TTJ 235152 ITD 320

Sections most often in play

Section 153CSection 131Section 132(4)Section 292CSection 132(4A)Section 271AABSection 69Section 132

Issues it is cited on

section 153c(1)section 132(4a)section 292csection 34satisfaction notesection 132(1)loose paperssection 153a(1)documents seizedsection 292section 158bsection 132a

Judgments citing Ltd. v. DCIT

Kanipakam Hari Prasad Reddy, Hyderabad vs. ACIT, Central Circle-2(3), Hyderabad

In the result, the appeal of assessee in ITA

ITA 20/HYD/2023[2016-17]Status: DisposedITAT Hyderabad28 Feb 2023AY 2016-17

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…during the course of search only against a searched person and, thus, no adverse inference could be drawn against the assessee on the basis of the possession of the diary with the third party. This was held in the case of SMC share brokers Ltd Vs DCIT [2008] 22 SOT 7 BY Hon'ble ITAT Delhi. (Paper Book page. No. 147 to 176). a) Where Assessing Officer made addition to assessee's income on basis of a document seized in course of search, in view of fact that document seized was both undated and unsigned and even taken at face value did not lead to further enquiry on behalf of Assessing Officer, impugned order of T…

Parige Venkat Ram Reddy, Kamareddy vs. ACIT, Central Circle-2(3), Hyderabad

In the result, the appeal of assessee in ITA

ITA 19/HYD/2023[2019-20]Status: DisposedITAT Hyderabad28 Feb 2023AY 2019-20

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…during the course of search only against a searched person and, thus, no adverse inference could be drawn against the assessee on the basis of the possession of the diary with the third party. This was held in the case of SMC share brokers Ltd Vs DCIT [2008] 22 SOT 7 BY Hon'ble ITAT Delhi. (Paper Book page. No. 147 to 176). a) Where Assessing Officer made addition to assessee's income on basis of a document seized in course of search, in view of fact that document seized was both undated and unsigned and even taken at face value did not lead to further enquiry on behalf of Assessing Officer, impugned order of T…

Parige Venkat Ram Reddy, Hyderabad vs. ACIT, Central Circle-2(3), Hyderabad

In the result, the appeal of assessee in ITA

ITA 18/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…during the course of search only against a searched person and, thus, no adverse inference could be drawn against the assessee on the basis of the possession of the diary with the third party. This was held in the case of SMC share brokers Ltd Vs DCIT [2008] 22 SOT 7 BY Hon'ble ITAT Delhi. (Paper Book page. No. 147 to 176). a) Where Assessing Officer made addition to assessee's income on basis of a document seized in course of search, in view of fact that document seized was both undated and unsigned and even taken at face value did not lead to further enquiry on behalf of Assessing Officer, impugned order of T…

Guduri Venkata Raju, Hyderabad vs. ACIT, Central Circle-2(3), Hyderabad

In the result, the appeal of assessee in ITA

ITA 17/HYD/2023[2019-20]Status: DisposedITAT Hyderabad28 Feb 2023AY 2019-20

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…during the course of search only against a searched person and, thus, no adverse inference could be drawn against the assessee on the basis of the possession of the diary with the third party. This was held in the case of SMC share brokers Ltd Vs DCIT [2008] 22 SOT 7 BY Hon'ble ITAT Delhi. (Paper Book page. No. 147 to 176). a) Where Assessing Officer made addition to assessee's income on basis of a document seized in course of search, in view of fact that document seized was both undated and unsigned and even taken at face value did not lead to further enquiry on behalf of Assessing Officer, impugned order of T…

Gudduri Venkata Raju, Hyderabad vs. ACIT, Central Circle-2(3), Hyderabad

In the result, the appeal of assessee in ITA

ITA 16/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…during the course of search only against a searched person and, thus, no adverse inference could be drawn against the assessee on the basis of the possession of the diary with the third party. This was held in the case of SMC share brokers Ltd Vs DCIT [2008] 22 SOT 7 BY Hon'ble ITAT Delhi. (Paper Book page. No. 147 to 176). a) Where Assessing Officer made addition to assessee's income on basis of a document seized in course of search, in view of fact that document seized was both undated and unsigned and even taken at face value did not lead to further enquiry on behalf of Assessing Officer, impugned order of T…

Tricities Security and Allied Services Private Limited, Hyderabad vs. ACIT, Central Circle-2(3), Hyderabad

In the result, the appeal of assessee in ITA

ITA 15/HYD/2023[2019-20]Status: DisposedITAT Hyderabad28 Feb 2023AY 2019-20

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…during the course of search only against a searched person and, thus, no adverse inference could be drawn against the assessee on the basis of the possession of the diary with the third party. This was held in the case of SMC share brokers Ltd Vs DCIT [2008] 22 SOT 7 BY Hon'ble ITAT Delhi. (Paper Book page. No. 147 to 176). a) Where Assessing Officer made addition to assessee's income on basis of a document seized in course of search, in view of fact that document seized was both undated and unsigned and even taken at face value did not lead to further enquiry on behalf of Assessing Officer, impugned order of T…

Tricities Security and Allied Services Private Limited, Hyderabad vs. ACIT, Central Circle-2(3), Hyderabad

In the result, the appeal of assessee in ITA

ITA 14/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Feb 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…during the course of search only against a searched person and, thus, no adverse inference could be drawn against the assessee on the basis of the possession of the diary with the third party. This was held in the case of SMC share brokers Ltd Vs DCIT [2008] 22 SOT 7 BY Hon'ble ITAT Delhi. (Paper Book page. No. 147 to 176). a) Where Assessing Officer made addition to assessee's income on basis of a document seized in course of search, in view of fact that document seized was both undated and unsigned and even taken at face value did not lead to further enquiry on behalf of Assessing Officer, impugned order of T…

Sanjay Garudapally, Hyderabad vs. ACIT, Central Circle-2(3), Hyderabad

In the result, the appeal of assessee in ITA

ITA 13/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…during the course of search only against a searched person and, thus, no adverse inference could be drawn against the assessee on the basis of the possession of the diary with the third party. This was held in the case of SMC share brokers Ltd Vs DCIT [2008] 22 SOT 7 BY Hon'ble ITAT Delhi. (Paper Book page. No. 147 to 176). a) Where Assessing Officer made addition to assessee's income on basis of a document seized in course of search, in view of fact that document seized was both undated and unsigned and even taken at face value did not lead to further enquiry on behalf of Assessing Officer, impugned order of T…

Sanjay Garudapally, Hyderabad vs. ACIT, Central Circle-2(3), Hyderabad

In the result, the appeal of assessee in ITA

ITA 12/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Feb 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…during the course of search only against a searched person and, thus, no adverse inference could be drawn against the assessee on the basis of the possession of the diary with the third party. This was held in the case of SMC share brokers Ltd Vs DCIT [2008] 22 SOT 7 BY Hon'ble ITAT Delhi. (Paper Book page. No. 147 to 176). a) Where Assessing Officer made addition to assessee's income on basis of a document seized in course of search, in view of fact that document seized was both undated and unsigned and even taken at face value did not lead to further enquiry on behalf of Assessing Officer, impugned order of T…

Garudapally Shruthi Gupta, Hyderabad vs. ACIT, Central Circle-2(3), Hyderabad

In the result, the appeal of assessee in ITA

ITA 11/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…during the course of search only against a searched person and, thus, no adverse inference could be drawn against the assessee on the basis of the possession of the diary with the third party. This was held in the case of SMC share brokers Ltd Vs DCIT [2008] 22 SOT 7 BY Hon'ble ITAT Delhi. (Paper Book page. No. 147 to 176). a) Where Assessing Officer made addition to assessee's income on basis of a document seized in course of search, in view of fact that document seized was both undated and unsigned and even taken at face value did not lead to further enquiry on behalf of Assessing Officer, impugned order of T…

Garudapally Shruthi Gupta, Hyderabad vs. ACIT, Central Circle-2(3), Hyderabad

In the result, the appeal of assessee in ITA

ITA 10/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Feb 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

…during the course of search only against a searched person and, thus, no adverse inference could be drawn against the assessee on the basis of the possession of the diary with the third party. This was held in the case of SMC share brokers Ltd Vs DCIT [2008] 22 SOT 7 BY Hon'ble ITAT Delhi. (Paper Book page. No. 147 to 176). a) Where Assessing Officer made addition to assessee's income on basis of a document seized in course of search, in view of fact that document seized was both undated and unsigned and even taken at face value did not lead to further enquiry on behalf of Assessing Officer, impugned order of T…

Deputy Commissioner of Income Tax, Circle- 4(1)(1), Bangalore vs. M/S. Lifestyle International Private Limited, Bangalore

In the result, the assessee’s appeal stands allowed and revenue’s appeal stands dismissed

ITA 93/BANG/2020[2013-14]Status: DisposedITAT Bangalore18 Nov 2022AY 2013-14

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2013-14 M/S. Lifestyle International Pvt. Ltd., 77, Town Centre, The Deputy Building No. 3, Commissioner Of West Wing, Income Tax, Off Hal Airport Road, Circle – 4(1)(1), Yamlur, Vs. Bengaluru. Bengaluru – 560 037. Pan: Aaacl2937J Appellant Respondent & Assessment Year : 2013-14 (By Revenue)

Section 2Section 37Section 43(6)(c)Section 50B

…see for subsequent years to reflect true and fair view of profit and loss, and the state of affair of the business. 5.5 He also submitted that Coordinate Bench of this Tribunal in case of Quality Engineering & Software Technologies (P) Ltd. reported in (2015) 152 ITD 320 has held that provision for losses incurred on derivative contracts was an allowable expenditure. This Tribunal observed that, there was an existing contract with a binding obligation accrued against the assessee when it entered into forward contracts. This Tribunal held that, the forward contracts are in respect of consideration for exports proc…

Assistant Commissioner of Income Tax, Central Circel-2(1), Bangalore vs. Sri Mathikere Ramaiah Seetharam, Bangalore

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

ITA 544/BANG/2021[2016-17]Status: DisposedITAT Bangalore07 Nov 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Nagin Khincha &For Respondent: Shri M. Mathivanan, D.R
Section 131Section 132(4)Section 153CSection 45(2)

…133, 8137,8138,8136, 8135 & 8132/Mum/2010 Assessment years: 2002-03 to 2007-08 • V. K. Fiscal Services Pvt. Ltd. v. DCIT (Delhi)(Trib.) ITA nos. 5460.5461, 5462,. 5463, 5464 and 5465/Del/2012 AYs 2004-05 to 2009-10 • DSL Properties (P.) Ltd. v. Dy. CIT (2013) 60 SOT 88 (URO)(Delhi)(Trib.) • ACIT .v. Inlay Marketing Pvt. Ltd(2015) 167 TTJ 273 (Delhi)(Trib.) • Pepsi Foods P. Ltd. .v. ACIT (2014) 367 ITR 112 (Delhi)(HC) • CIT .v. Gopi Apartment (2014) 365 ITR 411 (All.)(HC) • DCIT.v. Akash Arogya Mindir P.Ltd. (2015) 167 TTJ 578/ 114 DTR 61 (Delhi)(Trib.) • ACIT v. Surbhi Sen Jindal (2018) 68 ITR 12(SN) (Patna) (Tri…

Assistant Commissioner of Income Tax, Central Circel-2(1), Bangalore vs. Sri Mathikere Ramaiah Seetharam, Bangalore

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

ITA 543/BANG/2021[2015-16]Status: DisposedITAT Bangalore07 Nov 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Nagin Khincha &For Respondent: Shri M. Mathivanan, D.R
Section 131Section 132(4)Section 153CSection 45(2)

…133, 8137,8138,8136, 8135 & 8132/Mum/2010 Assessment years: 2002-03 to 2007-08 • V. K. Fiscal Services Pvt. Ltd. v. DCIT (Delhi)(Trib.) ITA nos. 5460.5461, 5462,. 5463, 5464 and 5465/Del/2012 AYs 2004-05 to 2009-10 • DSL Properties (P.) Ltd. v. Dy. CIT (2013) 60 SOT 88 (URO)(Delhi)(Trib.) • ACIT .v. Inlay Marketing Pvt. Ltd(2015) 167 TTJ 273 (Delhi)(Trib.) • Pepsi Foods P. Ltd. .v. ACIT (2014) 367 ITR 112 (Delhi)(HC) • CIT .v. Gopi Apartment (2014) 365 ITR 411 (All.)(HC) • DCIT.v. Akash Arogya Mindir P.Ltd. (2015) 167 TTJ 578/ 114 DTR 61 (Delhi)(Trib.) • ACIT v. Surbhi Sen Jindal (2018) 68 ITR 12(SN) (Patna) (Tri…

Assistant Commissioner of Income Tax, Central Circel-2(1), Bangalore vs. Sri Mathikere Ramaiah Seetharam, Bangalore

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

ITA 542/BANG/2021[2014-15]Status: DisposedITAT Bangalore07 Nov 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Nagin Khincha &For Respondent: Shri M. Mathivanan, D.R
Section 131Section 132(4)Section 153CSection 45(2)

…133, 8137,8138,8136, 8135 & 8132/Mum/2010 Assessment years: 2002-03 to 2007-08 • V. K. Fiscal Services Pvt. Ltd. v. DCIT (Delhi)(Trib.) ITA nos. 5460.5461, 5462,. 5463, 5464 and 5465/Del/2012 AYs 2004-05 to 2009-10 • DSL Properties (P.) Ltd. v. Dy. CIT (2013) 60 SOT 88 (URO)(Delhi)(Trib.) • ACIT .v. Inlay Marketing Pvt. Ltd(2015) 167 TTJ 273 (Delhi)(Trib.) • Pepsi Foods P. Ltd. .v. ACIT (2014) 367 ITR 112 (Delhi)(HC) • CIT .v. Gopi Apartment (2014) 365 ITR 411 (All.)(HC) • DCIT.v. Akash Arogya Mindir P.Ltd. (2015) 167 TTJ 578/ 114 DTR 61 (Delhi)(Trib.) • ACIT v. Surbhi Sen Jindal (2018) 68 ITR 12(SN) (Patna) (Tri…

M/S. Biocon Limited, Bengaluru vs. Commissioner of Income Tax, Ltu, Bengaluru

In the result, the appeal filed by the assessee is allowed on the legal issue raised in ground no

ITA 1858/BANG/2018[2010-11]Status: DisposedITAT Bangalore09 Jun 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2010-11 The Joint M/S. Biocon Ltd., Commissioner Of 20Th Km, Hosur Road, Income-Tax, Electronic City, Large Tax Payers Bangalore – 560 100. Unit [Ltu], Pan: Aaacb7461R Vs. Bangalore. Appellant Respondent : Shri Padam Chand Khincha, Assessee By Ca Revenue By : Shri Pradeep Kumar, Cit Dr Date Of Hearing : 20-04-2022 Date Of Pronouncement : 09-06-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 28.03.2018 Passed By Ld.Cit(A)-3, Bangalore For A.Y. 2010-11 On Following Grounds Of Appeal: “The Grounds Mentioned Herein Below Are Independent & Without Prejudice To The Other Grounds Preferred By The Appellant. 1. That On Facts & Circumstances Of The ' Case & In Law, The Order Passed By The Learned Commissioner Of Income-Tax Appeals ["Cit(A)"] Dated March 28, 2018 Under Section 250 Of The Income-Tax Act, 1961 ("The Act") For Ay 2010-11 To The Extent Prejudicial To The Appellant, Is Bad In Law & Facts & Liable To Be Quashed. 2. Scope Of Re-Assessment Proceedings

For Respondent: Shri Padam Chand Khincha
Section 147Section 250Section 35

…acts and circumstances of the case, the Learned CIT(A) erred in law and on facts in not considering the decision of the Hon'ble Bangalore Tribunal in the case of Quality Engineering & Software Technologies (P.) Ltd. Vs Deputy Commissioner of Income Tax 12015] 152 ITD 320 (Bangalore - Trib.) wherein the restatement of assets and liabilities was considered as an allowable expenditure under MAT. 5.7 That on facts and circumstances of the case, the Learned CIT(A) erred in law and on facts in disregarding the ruling of the Honourable Supreme Court in the case of CIT v. Woodward Governor India (P.) Ltd. [2009] 312 ITR…

M/S. Devaraj Urs Educational Trust for Backward Classes (Regd), Kolar vs. Principal Commissioner of Income Tax (Central), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 155/BANG/2022[2020-21]Status: DisposedITAT Bangalore08 Jun 2022AY 2020-21

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: Na

For Appellant: Sri Ramasubramaniyan, A.RFor Respondent: Sri Pradeep Kumar, D.R
Section 11Section 12ASection 132Section 143(2)Section 143(3)Section 153A

…It is settled principle that whenever the assessee desires, he can have access to all information, whether favourable or adverse to him as laid down in Suraj Mall Mohta & Co. v. A.V. Visvanatha Sastri [1954] 26 ITR 1 (SC), SMC Share Brokers Ltd. v. CIT [2008] 22 SOT 7 (Delhi)(URO), CIT v. Simon Carves Ltd. [1976] 105 ITR 212 (SC). In this case the assessee has every reason to believe that the evidences tendered by the parents, who were Departmental witnesses, were all favourable to assessee and therefore, the Department was apprehensive of providing these statements as the same M/s. Devaraj Urs Educational Trust…

M/S. Edelweiss Broking Ltd. ( Amalgamating Company Edelweiss Financial Advisors Ltd.), Ahmedabad vs. The ACIT, Circle-1(3), Ahmedabad

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

ITA 319/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad28 Feb 2022AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri Biren Shah & Gulab Thakor, ARsFor Respondent: Shri Mukesh Jain, Sr. DR
Section 143(3)Section 73

…Accordingly, we conclude that the provisions of explanation to Section 73 of the Act cannot be applied to the case on hand. In holding so we find support and guidance from the order of this Tribunal in the case of Parker securities Ltd versus DCIT reported in 102 TTJ 235 wherein it was held as under: “Explanation to Section 73 provides that where any part of the business of a company (other than certain specified companies as mentioned in the Explanation) consists in the purchase and sale of shares of other companies, such company shall, for the purposes of this Section, be deemed to be carrying on a speculation…

Sh Tech Park Developers Pvt. Ltd., New Delhi vs. DCIT, Circle- 23(1), New Delhi

In the result, the appeals of the assessee are allowed

ITA 480/DEL/2018[2013-14]Status: DisposedITAT Delhi20 Jan 2022AY 2013-14

Bench: Sh. Amit Shukladr. B. R. R. Kumar(Through Video Conferencing) Ita No. 6807/Del/2017 : Asstt. Year : 2014-15 Ita No. 480/Del/2018 : Asstt. Year : 2013-14 Sh Tech Park Developers Pvt. Ltd., Vs Dcit, 621-A, 6Th Floor, Devika Tower, Nehru Circle-23(1), Place, New Delhi-110019 New Delhi (Appellant) (Respondent) Pan No. Aalcs0818E

For Appellant: Sh. C. S. Agarwal, Sr. AdvFor Respondent: Sh. H. K. Choudhary, CIT DR
Section 194ASection 201(1)Section 40

…Hence, the premium cannot be brought to tax. Further, placing reliance on the judgment of, a. CIT Vs. Tungabhadra Industries Ltd. 2 SCL 42 (Calcutta) b. Shree Rajasthan Synyex Ltd. Vs. Union of India 1985 taxmann.com 413 (Rajasthan) c. Raymonds Ltd. Vs. DCIT 80 TTJ 120 (Mumbai) d. CIT Vs. MP Financial Corporation 180 ITR 327 (MP) e. Madras Industrial Investments Corpn. Ltd. Vs. CIT 12 SCL 139 (SC), 4 SH Tech Park Developers Pvt. Ltd. we, hereby hold that the expenditure involved in redemption of debentures is an allowable revenue expenditure. 9. In the result, the appeals of the assessee are allowed. Order Pron…

Sh Tech Park Developers Pvt. Ltd., New Delhi vs. DCIT, Circle- 23(1), New Delhi

In the result, the appeals of the assessee are allowed

ITA 6807/DEL/2017[2014-15]Status: DisposedITAT Delhi20 Jan 2022AY 2014-15

Bench: Sh. Amit Shukladr. B. R. R. Kumar(Through Video Conferencing) Ita No. 6807/Del/2017 : Asstt. Year : 2014-15 Ita No. 480/Del/2018 : Asstt. Year : 2013-14 Sh Tech Park Developers Pvt. Ltd., Vs Dcit, 621-A, 6Th Floor, Devika Tower, Nehru Circle-23(1), Place, New Delhi-110019 New Delhi (Appellant) (Respondent) Pan No. Aalcs0818E

For Appellant: Sh. C. S. Agarwal, Sr. AdvFor Respondent: Sh. H. K. Choudhary, CIT DR
Section 194ASection 201(1)Section 40

…Hence, the premium cannot be brought to tax. Further, placing reliance on the judgment of, a. CIT Vs. Tungabhadra Industries Ltd. 2 SCL 42 (Calcutta) b. Shree Rajasthan Synyex Ltd. Vs. Union of India 1985 taxmann.com 413 (Rajasthan) c. Raymonds Ltd. Vs. DCIT 80 TTJ 120 (Mumbai) d. CIT Vs. MP Financial Corporation 180 ITR 327 (MP) e. Madras Industrial Investments Corpn. Ltd. Vs. CIT 12 SCL 139 (SC), 4 SH Tech Park Developers Pvt. Ltd. we, hereby hold that the expenditure involved in redemption of debentures is an allowable revenue expenditure. 9. In the result, the appeals of the assessee are allowed. Order Pron…