M.P. Financial Corporation v. CIT

165 ITR 765High Court1987#2619 most cited

What is M.P. Financial Corporation v. CIT authority for?

Discount on debentures and expenses incurred for obtaining loans are revenue expenditures, eligible for deduction proportionately over the respective accounting periods for which the debentures or loans remain outstanding.

44

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2009 to 2026.

Also referred to as

M.P. Financial Corporation v. CIT · 165 ITR 765 · section 37(1) · section 35ABA · section 35ABB · discount on debentures · amortization of debenture discount · expenses for obtaining loans · revenue expenditure · proportionate deduction · business deduction

Sections most often in play

Section 37(1)Section 194HSection 271(1)(c)Section 35ABASection 35ABBSection 40(a)(ia)Section 143(3)Section 263

Issues it is cited on

section 35abbsection 194hintangible assetssection 30section 35section 201(1)profits and gains of business or professionsection 253section 32section 201section 40(a)section 40(a)(ia)

Judgments citing M.P. Financial Corporation v. CIT

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

ITA 1480/HYD/2025[2011-12]Status: DisposedITAT Hyderabad27 Mar 2026AY 2011-12
Section 139Section 143(2)Section 143(3)Section 147Section 148Section 149Section 250

…ture" as used in Section 37 may, in the circumstances of a particular case, cover an amount which is really a "loss" even though the said amount has not gone out from the pocket of the assessee. 14. In the case of M.P. Financial Corporation v. CIT reported in 165 ITR 765 the Madhya Pradesh High Court has held that the expression "expenditure" as used in Section 37 may, in the circumstances of a particular case, cover an amount which is a "loss" even though the said 16 Country Club Hospitality & Holidays Limited amount has not gone out from the pocket of the assessee. This view of the Madhya Pradesh High Court h…

JCIT (OSD), CENTRAL CIRCLE-20, JAHANDEWALAN vs. AVANTHA REALTY LTD. (EARLIER KNOW AS JANPATH INVESTMENT HOLDING LTD.), DELHI

Appeal of the Revenue is partly allowed

ITA 566/KOL/2024[1999-00]Status: DisposedITAT Kolkata20 Nov 2025AY 1999-00

Bench: Appropriate

Section 250Section 263

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, KOLKATA SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER I.T.A. No. 566/Kol/2024 Assessment Year 1999-2000 DCIT, Central Circle,20, Room No. 269A, 2nd Floor, ARA, Centre E-2, Jhandewalan, New Delhi – 110055 ……..…...…………….... Appellant vs. Avantha Realty Ltd., (Previous known as Janpath Investment & Holding Ltd.), 124, Thapar House, Janpath, Central Delhi – Delhi - 110001 [PAN: AAACJ8030A] ……..…...…………….... Respondent Appearances by: Assessee represented by : Sanjay Bhattacharya, FCA Department represented by : P.N. Barnwal, CIT-DR Da…

ACIT CIRCLE 25(1) , DELHI vs. TATA TELESERVICES LTD. , DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 17/DEL/2022[2016-17]Status: DisposedITAT Delhi26 Aug 2025AY 2016-17

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

…spect of the proportionate part of discount of Rs. 12,500 over the relevant accounting period in question. In this connection, we agree with the reasoning and conclusion of the Madhya Pradesh High Court in the case of M. P. Financial Corporation v. CIT (1987) 165 ITR 765. The view that we have taken is also in conformity with the accounting practice of showing the discount in the "discount on debentures account which is written off over the period of the debentures." The Hon'ble Supreme Court has categorically held that discount on debenture which has been amortised qualify as revenue expenditure. Similarly, expe…

TATA TELESERVICES LTD.,NEW DELHI vs. DCIT, CIRCLE-25(1), NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 337/DEL/2021[2016-17]Status: DisposedITAT Delhi26 Aug 2025AY 2016-17

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

…spect of the proportionate part of discount of Rs. 12,500 over the relevant accounting period in question. In this connection, we agree with the reasoning and conclusion of the Madhya Pradesh High Court in the case of M. P. Financial Corporation v. CIT (1987) 165 ITR 765. The view that we have taken is also in conformity with the accounting practice of showing the discount in the "discount on debentures account which is written off over the period of the debentures." The Hon'ble Supreme Court has categorically held that discount on debenture which has been amortised qualify as revenue expenditure. Similarly, expe…

DCIT CIRCLE 25(1), NEW DELHI vs. TATA TELESERVICES LTD., NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 5927/DEL/2019[2015-16]Status: DisposedITAT Delhi26 Aug 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

…spect of the proportionate part of discount of Rs. 12,500 over the relevant accounting period in question. In this connection, we agree with the reasoning and conclusion of the Madhya Pradesh High Court in the case of M. P. Financial Corporation v. CIT (1987) 165 ITR 765. The view that we have taken is also in conformity with the accounting practice of showing the discount in the "discount on debentures account which is written off over the period of the debentures." The Hon'ble Supreme Court has categorically held that discount on debenture which has been amortised qualify as revenue expenditure. Similarly, expe…

DCIT CIRCLE 25(1), NEW DELHI vs. TATA TELESERVICES LTD., NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 5926/DEL/2019[2014-15]Status: DisposedITAT Delhi26 Aug 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

…spect of the proportionate part of discount of Rs. 12,500 over the relevant accounting period in question. In this connection, we agree with the reasoning and conclusion of the Madhya Pradesh High Court in the case of M. P. Financial Corporation v. CIT (1987) 165 ITR 765. The view that we have taken is also in conformity with the accounting practice of showing the discount in the "discount on debentures account which is written off over the period of the debentures." The Hon'ble Supreme Court has categorically held that discount on debenture which has been amortised qualify as revenue expenditure. Similarly, expe…

DCIT CIRCLE - 25(1), NEW DELHI vs. TATA TELESERVICES LTD.,, NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 5925/DEL/2019[2013-14]Status: DisposedITAT Delhi26 Aug 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

…spect of the proportionate part of discount of Rs. 12,500 over the relevant accounting period in question. In this connection, we agree with the reasoning and conclusion of the Madhya Pradesh High Court in the case of M. P. Financial Corporation v. CIT (1987) 165 ITR 765. The view that we have taken is also in conformity with the accounting practice of showing the discount in the "discount on debentures account which is written off over the period of the debentures." The Hon'ble Supreme Court has categorically held that discount on debenture which has been amortised qualify as revenue expenditure. Similarly, expe…

DCIT CIRCLE - 25(1), NEW DELHI vs. TATA TELESERVICES LTD.,, NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 5924/DEL/2019[2012-13]Status: DisposedITAT Delhi26 Aug 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

…spect of the proportionate part of discount of Rs. 12,500 over the relevant accounting period in question. In this connection, we agree with the reasoning and conclusion of the Madhya Pradesh High Court in the case of M. P. Financial Corporation v. CIT (1987) 165 ITR 765. The view that we have taken is also in conformity with the accounting practice of showing the discount in the "discount on debentures account which is written off over the period of the debentures." The Hon'ble Supreme Court has categorically held that discount on debenture which has been amortised qualify as revenue expenditure. Similarly, expe…

TATA TELESERVICES LTD.,,NEW DELHI vs. ACIT CIRCLE - 25(1), NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 5666/DEL/2019[2013-14]Status: DisposedITAT Delhi26 Aug 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

…spect of the proportionate part of discount of Rs. 12,500 over the relevant accounting period in question. In this connection, we agree with the reasoning and conclusion of the Madhya Pradesh High Court in the case of M. P. Financial Corporation v. CIT (1987) 165 ITR 765. The view that we have taken is also in conformity with the accounting practice of showing the discount in the "discount on debentures account which is written off over the period of the debentures." The Hon'ble Supreme Court has categorically held that discount on debenture which has been amortised qualify as revenue expenditure. Similarly, expe…

TATA TELESERVICES LTD.,,NEW DELHI vs. ACIT CIRCLE - 25(1), NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 5665/DEL/2019[2012-13]Status: DisposedITAT Delhi26 Aug 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

…spect of the proportionate part of discount of Rs. 12,500 over the relevant accounting period in question. In this connection, we agree with the reasoning and conclusion of the Madhya Pradesh High Court in the case of M. P. Financial Corporation v. CIT (1987) 165 ITR 765. The view that we have taken is also in conformity with the accounting practice of showing the discount in the "discount on debentures account which is written off over the period of the debentures." The Hon'ble Supreme Court has categorically held that discount on debenture which has been amortised qualify as revenue expenditure. Similarly, expe…

TATA TELESERVICES LTD.,NOIDA vs. ACIT, CIRCLE- 25(1), NEW DELHI

Accordingly, this issue is raised in grounds of appeal No.4 of the Revenue in all these years is dismissed

ITA 4150/DEL/2017[2011-12]Status: DisposedITAT Delhi26 Aug 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri Manish Agarwalita No.5665/Del/2019 (Assessment Year 2012-13)

Section 37(1)

…spect of the proportionate part of discount of Rs. 12,500 over the relevant accounting period in question. In this connection, we agree with the reasoning and conclusion of the Madhya Pradesh High Court in the case of M. P. Financial Corporation v. CIT (1987) 165 ITR 765. The view that we have taken is also in conformity with the accounting practice of showing the discount in the "discount on debentures account which is written off over the period of the debentures." The Hon'ble Supreme Court has categorically held that discount on debenture which has been amortised qualify as revenue expenditure. Similarly, expe…

VENTURE LIGHTING INDIA LIMITED,CHENNAI vs. ACIT CORPORATE CIRCLE 3(2), CHENNAI

In the result, considering the factual matrix in the instant case, material available on record and the judicial precedence discussed above, the appeals filed by the assessee in ITA Nos

ITA 1209/CHNY/2019[2010-11]Status: DisposedITAT Chennai04 Mar 2022AY 2010-11

Bench: Shri Mahavir Singhand Shri Girish Agrawalआयकर अपील सं./Ita Nos.: 2945 & 2946/Chny/2018 & 1209/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13, 2014-15 & 2010-11 The Acit / Dcit, M/S. Venture Lighting India Limited, Corporate Circle – 3(2), V. Plot No.A-30, D5, Phase-Ii, Chennai. Zone-B, Mepz, Tambaram, Chennai – 600 045. Pan: Aaaca 9284H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri G. Johnson, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 03.03.2022 घोषणा क" तार"ख/Date Of Pronouncement : 04.03.2022 आदेश /O R D E R Per Girish Agrawal, Am: The Two Appeals In Ita Nos. 2945 & 2946/Chny/2018 By The Assessee Are Arising Out Of Common Order Of Learned Commissioner Of Income Tax (Appeals)-11, Chennai In Ita Nos.112/16-17 & 160/17-18, Dated 29.09.2018. The Assessments Were Framed By The Acit / Dcit, Corporate Circle 3(2), Chennai For The Assessment Years 2012-13 &

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri G. Johnson, Addl.CIT
Section 143(3)

…true and correct profits. Hence, in the present case before us also the facts being identical, we respectfully follow the said judgment. The Hon’ble Supreme Court in para 14 & 15 held as under:- 14. In the case of M.P. Financial Corporation v. CIT reported in 165 ITR 765 the Madhya Pradesh High Court has held that the expression “expenditure” 8 I.T.A. Nos.2945 & 2946/Chny/2018 1209/Chny/2019 as used in Section 37 may, in the circumstances of a particular case, cover an amount which is a “loss” even though the said amount has not gone out from the pocket of the assessee. This view of the Madhya Pradesh High Cour…

VENTURE LIGHTING INDIA LIMITED,CHENNAI vs. ACIT CORPORATE CIRCLE 3(2), CHENNAI

In the result, considering the factual matrix in the instant case, material available on record and the judicial precedence discussed above, the appeals filed by the assessee in ITA Nos

ITA 2946/CHNY/2018[2014-15]Status: DisposedITAT Chennai04 Mar 2022AY 2014-15

Bench: Shri Mahavir Singhand Shri Girish Agrawalआयकर अपील सं./Ita Nos.: 2945 & 2946/Chny/2018 & 1209/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13, 2014-15 & 2010-11 The Acit / Dcit, M/S. Venture Lighting India Limited, Corporate Circle – 3(2), V. Plot No.A-30, D5, Phase-Ii, Chennai. Zone-B, Mepz, Tambaram, Chennai – 600 045. Pan: Aaaca 9284H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri G. Johnson, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 03.03.2022 घोषणा क" तार"ख/Date Of Pronouncement : 04.03.2022 आदेश /O R D E R Per Girish Agrawal, Am: The Two Appeals In Ita Nos. 2945 & 2946/Chny/2018 By The Assessee Are Arising Out Of Common Order Of Learned Commissioner Of Income Tax (Appeals)-11, Chennai In Ita Nos.112/16-17 & 160/17-18, Dated 29.09.2018. The Assessments Were Framed By The Acit / Dcit, Corporate Circle 3(2), Chennai For The Assessment Years 2012-13 &

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri G. Johnson, Addl.CIT
Section 143(3)

…true and correct profits. Hence, in the present case before us also the facts being identical, we respectfully follow the said judgment. The Hon’ble Supreme Court in para 14 & 15 held as under:- 14. In the case of M.P. Financial Corporation v. CIT reported in 165 ITR 765 the Madhya Pradesh High Court has held that the expression “expenditure” 8 I.T.A. Nos.2945 & 2946/Chny/2018 1209/Chny/2019 as used in Section 37 may, in the circumstances of a particular case, cover an amount which is a “loss” even though the said amount has not gone out from the pocket of the assessee. This view of the Madhya Pradesh High Cour…

VENTURE LIGHTING INDIA LIMITED,CHENNAI vs. ACIT CORPORATE CIRCLE 3(2), CHENNAI

In the result, considering the factual matrix in the instant case, material available on record and the judicial precedence discussed above, the appeals filed by the assessee in ITA Nos

ITA 2945/CHNY/2018[2012-13]Status: DisposedITAT Chennai04 Mar 2022AY 2012-13

Bench: Shri Mahavir Singhand Shri Girish Agrawalआयकर अपील सं./Ita Nos.: 2945 & 2946/Chny/2018 & 1209/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13, 2014-15 & 2010-11 The Acit / Dcit, M/S. Venture Lighting India Limited, Corporate Circle – 3(2), V. Plot No.A-30, D5, Phase-Ii, Chennai. Zone-B, Mepz, Tambaram, Chennai – 600 045. Pan: Aaaca 9284H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri G. Johnson, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 03.03.2022 घोषणा क" तार"ख/Date Of Pronouncement : 04.03.2022 आदेश /O R D E R Per Girish Agrawal, Am: The Two Appeals In Ita Nos. 2945 & 2946/Chny/2018 By The Assessee Are Arising Out Of Common Order Of Learned Commissioner Of Income Tax (Appeals)-11, Chennai In Ita Nos.112/16-17 & 160/17-18, Dated 29.09.2018. The Assessments Were Framed By The Acit / Dcit, Corporate Circle 3(2), Chennai For The Assessment Years 2012-13 &

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri G. Johnson, Addl.CIT
Section 143(3)

…true and correct profits. Hence, in the present case before us also the facts being identical, we respectfully follow the said judgment. The Hon’ble Supreme Court in para 14 & 15 held as under:- 14. In the case of M.P. Financial Corporation v. CIT reported in 165 ITR 765 the Madhya Pradesh High Court has held that the expression “expenditure” 8 I.T.A. Nos.2945 & 2946/Chny/2018 1209/Chny/2019 as used in Section 37 may, in the circumstances of a particular case, cover an amount which is a “loss” even though the said amount has not gone out from the pocket of the assessee. This view of the Madhya Pradesh High Cour…

M/S INFOSYS BPM LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-3 , BANGALORE

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

ITA 2884/BANG/2018[2009-10]Status: DisposedITAT Bangalore22 Nov 2021AY 2009-10

Bench: Shri George George K. & Shri B.R. Baskaranassessment Year:2009-10

For Appellant: Shri Padamchand Khincha, A.RFor Respondent: Shri Sumer Singh, D.R
Section 10ASection 115JSection 143(3)Section 14ASection 40

…s. 37 may, in the circumstances of a particular case, cover an amount which is really a "loss" even though the said amount has not gone out from the pocket of the assessee. 14. In the case of M.P. Financial Corporation v. CIT [1986] 51 CTR (MP) 249 : (1987) 165 ITR 765 (MP) the Madhya Pradesh High Court has held that the expression "expenditure" as used in s. 37 may, in the circumstances of a particular case, cover an amount which is a "loss" even though the said amount has not gone out from the pocket of the assessee. This view of the Madhya Pradesh High Court has been approved by this Court in the case of Mad…

GMR HOSPITALITY AND RETAIL LIMITED (SUCCESSOR TO HYDERABAD DUTY FREE RETAIL LIMITED),HYDERABAD vs. INCOME TAX OFFICER, WARD-2(2), HYDERABAD

In the result, appeal of the assessee is allowed

ITA 325/HYD/2020[2016-17]Status: DisposedITAT Hyderabad16 Sept 2021AY 2016-17

Bench: Shri A. Mohan Alankamony & Shri S.S. Godaraa.Y. 2016-17 Gmr Hospitality & Retail Vs. Income Tax Officer, Limited (Successor Of Ward-2(2), Hyderabad Duty Free Retail Hyderabad. Limited), Hyderabad. Pan: Aadcg 2928 F (Appellant) (Respondent) Assessee By Shri Sunil Jain, Ar Revenue By Smt. M. Narmada, Dr Date Of Hearing: 02/09/2021 Date Of Pronouncement: 16/09/2021 Order

Section 143(3)Section 145Section 28Section 29Section 37Section 37(1)

…penditure" as used in section 37 may, in the circumstances of a particular case, cover an amount which is really a "loss" even though the said amount has not gone out from the pocket of the assessee. 14. In the case of M.P. Financial Corporation v. CIT [1987] 165 ITR 765 the Madhya Pradesh High Court has held that the expression "expenditure" as used in section 37 may, in the circumstances of a particular case, cover an amount which is a "loss" even though the said amount has not gone out from the pocket of the assessee. This view of the Madhya Pradesh High Court has been approved by this Court in the case of Mad…

CARLSON HOSPITALITY MARKETING (INDIA) PVT. LTD.,,GURGAON vs. DCIT, CIRCLE-3(1), NEW DELHI

The appeal of the assessee is allowed

ITA 4192/DEL/2018[2011-12]Status: DisposedITAT Delhi14 Sept 2021AY 2011-12

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

Section 143Section 143(1)Section 143(2)Section 234ASection 68

…IT Vs. Woodward Governor India Pvt. Ltd. 312 ITR 254 (S.C) as well as Oil and Natural Gas Corporation Ltd. Vs. CIT 332 ITR 180 (S.C). The Ld. AR also relied upon the decision of the Hon’ble Madhya Pradesh High Court in case of MP Financial Corporation Vs. CIT 165 ITR 765. 9. The Ld. DR relied upon the order of the CIT(A) and Assessment Order. 10. We have heard both the parties and perused all the relevant materials available on record. The loss suffered by the assessee on account of the exchange difference on the particular date is indicated in the balance sheet and the same is an item of expenditure u/s 37(1) o…

THE PR COMMISSIONER OF INCOME TAX vs. M/S MPHASIS LTD

The appeal is dismissed accordingly

ITA/62/2018HC Karnataka24 Feb 2021

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

Section 10BSection 143(3)Section 144Section 260

…in Section 37 may, in the circumstances of a particular case, cover an amount which is really a "loss" even though the said amount has not gone out from the pocket of the assessee. 14. In the case of M.P. Financial Corporation v. CIT reported in (1987) 165 ITR 765 the Madhya Pradesh High Court has held that the expression "expenditure" as used in Section 37 may, in the circumstances of a particular case, cover an amount which is a "loss" even though the said amount has not gone out from the pocket of the assessee. This view of the Madhya Pradesh High Court has been approved by this Court in the case…

AESSEAL INDIA PVT.LTD,,PUNE vs. INCOME-TAX OFFICER, WARD - 1(4),, PUNE

In the result, the appeal in ITA No

ITA 2203/PUN/2017[2014-15]Status: DisposedITAT Pune29 Oct 2020AY 2014-15
For Appellant: Shri Kishor PhadkeFor Respondent: Shri Mahadevan A.M. Krishanan
Section 143(1)Section 143(3)Section 43A

…e dictum of the Hon’ble Supreme Court in the case of Woodward Governor India Pvt. Ltd. (supra) wherein the Hon’ble Apex Court had quoted with approval of the decision of the Hon’ble Madhya Pradesh High Court in the case of M. P. Financial Corporation vs. CIT, 165 ITR 765 wherein it was held that the term “expenditure” covers even a case of loss even though the said amount has not gone out from the pocket of the assessee. The Hon’ble Apex Court further observed that the decision of the Hon’ble Madhya Pradesh High Court in the case of M. P. Financial Corporation (supra) was approved by the Hon’ble Apex Court in the…

AESSEAL INDIA PVT.LTD,,PUNE vs. INCOME-TAX OFFICER, WARD - 1(4),, PUNE

In the result, the appeal in ITA No

ITA 2202/PUN/2017[2012-13]Status: DisposedITAT Pune29 Oct 2020AY 2012-13
For Appellant: Shri Kishor PhadkeFor Respondent: Shri Mahadevan A.M. Krishanan
Section 143(1)Section 143(3)Section 43A

…e dictum of the Hon’ble Supreme Court in the case of Woodward Governor India Pvt. Ltd. (supra) wherein the Hon’ble Apex Court had quoted with approval of the decision of the Hon’ble Madhya Pradesh High Court in the case of M. P. Financial Corporation vs. CIT, 165 ITR 765 wherein it was held that the term “expenditure” covers even a case of loss even though the said amount has not gone out from the pocket of the assessee. The Hon’ble Apex Court further observed that the decision of the Hon’ble Madhya Pradesh High Court in the case of M. P. Financial Corporation (supra) was approved by the Hon’ble Apex Court in the…

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M.P. Financial Corporation v. CIT (165 ITR 765) — Cited in 44 Judgments | BharatTax