Madras Industrial Investment Corporation Ltd. v. CIT

225 ITR 802Supreme Court of India1997#111 most cited

What is Madras Industrial Investment Corporation Ltd. v. CIT authority for?

An assessee has the option to amortize certain revenue expenses over multiple years for tax purposes, and tax authorities cannot take a contrary view. The case also clarifies the enduring benefit test for distinguishing capital and revenue expenditure.

568

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2008 to 2026.

Also referred to as

Madras Industrial Investment Corporation Ltd v CIT · 225 ITR 802 · Section 37(1) · revenue expenditure · capital expenditure · enduring benefit test · amortization of expenses · spreading revenue expenditure · assessee's option to amortize · mercantile system of accounting · commercial expediency

Sections most often in play

Section 143(3)Section 37(1)Section 153ASection 147Section 153CSection 132Section 14ASection 263

Issues it is cited on

enduring benefitsection 32(1)revenue expenditureintangible assetssection 32capital expendituresection 35commercial expediencysection 30book profitsamalgamationmercantile system of accounting

Judgments citing Madras Industrial Investment Corporation Ltd. v. CIT

ASST CIT 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3882/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

…hould be spread over the period to which the guarantee commission related and should be assessed proportionately. 30.3. It was submitted that, the principle laid down by Hon’ble Supreme Court in the case of Madras Industrial Investment Corporation reported in 225 ITR 802 and of by Hon’ble Punjab & Haryana High Court in the case of Punjab Tractors Co-operative Multipurpose Society Ltd. reported in 234 ITR 105 is clearly applicable to the case of the assessee. 30.4. The assessee also relied in decision of coordinate bench of this Tribunal wherein the issue was decided in favour of assessee subject to verification f…

STATE BANK OF INDIA,MUMBAI vs. ASST CIT CIR 2(2), MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3680/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

…hould be spread over the period to which the guarantee commission related and should be assessed proportionately. 30.3. It was submitted that, the principle laid down by Hon’ble Supreme Court in the case of Madras Industrial Investment Corporation reported in 225 ITR 802 and of by Hon’ble Punjab & Haryana High Court in the case of Punjab Tractors Co-operative Multipurpose Society Ltd. reported in 234 ITR 105 is clearly applicable to the case of the assessee. 30.4. The assessee also relied in decision of coordinate bench of this Tribunal wherein the issue was decided in favour of assessee subject to verification f…

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

…आयकर अपीलीय न्यायाधिकरण में, हैदराबाद ‘बी’ बेंच, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad “B” Bench, Hyderabad श्री मंजूनाथ जी, माननीय लेखा सदस्य एवं श्री रवीश सूद, माननीय न्याययक सदस्य SHRI G. MANJUNATHA, HON’BLE ACCOUNTANT MEMBER AND SHRI RAVISH SOOD, HON’BLE JUDICIAL MEMBER आयकरअपीलसं./I.T.A.No.1480/Hyd/2025 (निर्धारण वर्ा/ Assessment Year: 2011-12) Country Club Hospitality & Vs. The Deputy Commissioner of Holidays Limited, Income-tax, C/o. 6-3-655/2/3, Central Circle – 1(1), P. Murali and Co., Hyderabad. Chartered Accountants, Somajiguda, Hyderabad – 500082., PAN : AAACC8276B (अपीलार्थी/ Appel…

DCIT, GURGAON vs. ORIENT CRAFT LTD., NEW DELHI

ITA 3202/DEL/2017[2011-12]Status: DisposedITAT Delhi20 Mar 2026AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Salil Aggarwal, Sr. AdvFor Respondent: Ms. Monika Singh, CIT(DR)
Section 10BSection 14A

…ances of the case, the Ld. CIT(A) has erred in deleting the disallowance of product development expenses Rs. 8,27,46,723/- made by the AO by ignoring the decision of the Hon'ble Supreme Court in the case of Madras Industrial Investment Corporation Ltd. Vs CIT 225 ITR 802 and the Department's appeal against the decision of ITAT in assessee's own case for A.Y.'s 07-08 & 08-09 are pending before the Hon'ble High Court. (ii) On the facts and circumstances of the case, the Ld. CIT(A) has erred in rejecting the mandatory procedure adopted by the AO in making the disallowance of expenses u/s 14A of the Income Tax Act, 1…

DCIT, NEW DELHI vs. M/S. ORIENT CRAFT LTD., NEW DELHI

ITA 3773/DEL/2015[2009-10]Status: DisposedITAT Delhi20 Mar 2026AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Salil Aggarwal, Sr. AdvFor Respondent: Ms. Monika Singh, CIT(DR)
Section 10BSection 14A

…ances of the case, the Ld. CIT(A) has erred in deleting the disallowance of product development expenses Rs. 8,27,46,723/- made by the AO by ignoring the decision of the Hon'ble Supreme Court in the case of Madras Industrial Investment Corporation Ltd. Vs CIT 225 ITR 802 and the Department's appeal against the decision of ITAT in assessee's own case for A.Y.'s 07-08 & 08-09 are pending before the Hon'ble High Court. (ii) On the facts and circumstances of the case, the Ld. CIT(A) has erred in rejecting the mandatory procedure adopted by the AO in making the disallowance of expenses u/s 14A of the Income Tax Act, 1…

M/S. ORIENT CRAFT LTD.,NEW DELHI vs. DCIT, NEW DELHI

ITA 3626/DEL/2015[2010-11]Status: DisposedITAT Delhi20 Mar 2026AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Salil Aggarwal, Sr. AdvFor Respondent: Ms. Monika Singh, CIT(DR)
Section 10BSection 14A

…ances of the case, the Ld. CIT(A) has erred in deleting the disallowance of product development expenses Rs. 8,27,46,723/- made by the AO by ignoring the decision of the Hon'ble Supreme Court in the case of Madras Industrial Investment Corporation Ltd. Vs CIT 225 ITR 802 and the Department's appeal against the decision of ITAT in assessee's own case for A.Y.'s 07-08 & 08-09 are pending before the Hon'ble High Court. (ii) On the facts and circumstances of the case, the Ld. CIT(A) has erred in rejecting the mandatory procedure adopted by the AO in making the disallowance of expenses u/s 14A of the Income Tax Act, 1…

M/S. ORIENT CRAFT LTD.,NEW DELHI vs. DCIT, NEW DELHI

ITA 3625/DEL/2015[2009-10]Status: DisposedITAT Delhi20 Mar 2026AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Salil Aggarwal, Sr. AdvFor Respondent: Ms. Monika Singh, CIT(DR)
Section 10BSection 14A

…ances of the case, the Ld. CIT(A) has erred in deleting the disallowance of product development expenses Rs. 8,27,46,723/- made by the AO by ignoring the decision of the Hon'ble Supreme Court in the case of Madras Industrial Investment Corporation Ltd. Vs CIT 225 ITR 802 and the Department's appeal against the decision of ITAT in assessee's own case for A.Y.'s 07-08 & 08-09 are pending before the Hon'ble High Court. (ii) On the facts and circumstances of the case, the Ld. CIT(A) has erred in rejecting the mandatory procedure adopted by the AO in making the disallowance of expenses u/s 14A of the Income Tax Act, 1…

JCIT(OSD) RANGE-10, NEW DELHI, ITO, C.R. BUILDING vs. GWALIOR BYPASS PROJECT LTD., NEW ASHOK NAGAR, DELHI

In the result, the appeal of the revenue is dismissed

ITA 2896/DEL/2025[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganeshjcit(Osd), Vs. Gwalior Bypass Project Ltd, Range-10, New Delhi B-292, Chandrakanta Complex, Shop No. 2 & 3, Near Metro Pillar No. 161, New Ashok Nagar, New Delhi (Appellant) (Respondent) Pan: Aaccg6312J

For Appellant: Ms. Chinu Bhasin, AdvFor Respondent: Ms. Pooja Swaroop, CIT (DR)
Section 143(3)Section 32

…the Act. The Learned AO relying on the CBDT Circular No. 9 / 2014 allowed amortization over the life of annuity. The Learned AO also relied on the decision of the Hon’ble Supreme Court in the case of Madras Industrial Investment Corporation vs CIT reported in 225 ITR 802 (SC) which is also cited in the said Circular. The Learned CITA by following the order of order passed by this Tribunal in Assessee’s own case for assessment years 2014-15 and 2015-16 deleted the disallowance made on depreciation on highway projects. We find that the issue in dispute is squarely covered by the Special Bench’s decision of Hyderab…

INTERNATIONAL SEAPORT (HALDIA) PVT. LTD. ,KOLKATA vs. ACIT,CIR-12(1),, KOLKATA

In the result, appeal of the assessee is allowed

ITA 328/KOL/2023[2018-19]Status: DisposedITAT Kolkata11 Dec 2025AY 2018-19

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.328/Kol/2023 (निर्धारण वर्ा / Assessment Year : 2018-2019) International Seaport (Haldia) Vs Acit, Circle-12(1), Kolkata Private Limited, C/O S.N.Ghosh & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata-700001 Pan No. :Aaci 9468 D (अपीलधर्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्धाररती की ओर से /Assessee By Shri Somnath Ghosh, Ar रधजस्व की ओर से /Revenue By : Shri Santanu Ghosh, Sr.Dr सुनवाई की तारीख / Date Of Hearing : 11/12/2025 घोषणा की तारीख/Date Of Pronouncement : 11/12/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 06.02.2023 For The Assessment Year 2018-2019. 2. It Was Submitted By The Ld.Ar That Two Issues Are Involved In The Assessee’S Appeal, One Is The Denial Of The Deduction U/S.80Ia Of The Act In Respect Of Miscellaneous Income To An Extra Rs.4,99,372/- & The Second Issue Was Disallowance Of The Disallowance Of The Amortization Of The Leasehold Rent Allegedly By The Ao Claiming The Same To Be Claim Of Depreciation To An Extent Of Rs.42,32,776/-. It Was Submission That In Respect Of The One Number Imported Slewing Ring Roller Bearing From The Original Manufacturer Of The Same I.E. Rothe Erde, Germany, Which Was An Important & Expensive Spare Required For The Operation Of The Stacking &

For Respondent: Shri Santanu Ghosh, Sr.DR
Section 143(3)Section 80Section 80I

…the assessee cannot be treated as the "owner" of the property and cannot be allowed depreciation u/s 32(1)(ii) of the Act. In the said circular, the CBDT has also held, following the law laid down by Hon'ble Supreme Court in Madras Industrial Investment Corp 225 ITR 802 (SC), that the entire cost of construction and development of the infrastructure facility has to be amortized evenly over the period of the concessionaire agreement and allowed as business expenditure u/s 37(1) of the Act. Relevant extract of CBDT circular is as under: 6 4. There is no doubt that where the assessee incurs expenditure on a projec…

DCIT 2(3)(2), MUMBAI vs. ICICI BANK LTD, MUMBAI

In the result, ground no. 3 of appeal of

ITA 1550/MUM/2016[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

…been restricted on the ground that ICICI Bank Limited ITA No. 1550/Mum/2016 (AY 2009-10) they were required to spread over the period of concerned debentures and bond in accordance with decision of Supreme Court in Madras Industrial Development Corporation 225 ITR 802. The addition in A.Y. 2002-03 were upheld by ld. CIT(A) and that appeal at the time of assessment was pending. The assessing officer on the basis of order of his predecessor disallowed such expenses. The ld. CIT(A) on the prayer of assessee that in the event of success in appeal of A.Y. 2002-03, the deduction allowed in this year will be offer…

ICICI BANK LTD,MUMBAI vs. DCIT 2(3)(2), MUMBAI

In the result, ground no. 3 of appeal of

ITA 4418/MUM/2015[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

…been restricted on the ground that ICICI Bank Limited ITA No. 1550/Mum/2016 (AY 2009-10) they were required to spread over the period of concerned debentures and bond in accordance with decision of Supreme Court in Madras Industrial Development Corporation 225 ITR 802. The addition in A.Y. 2002-03 were upheld by ld. CIT(A) and that appeal at the time of assessment was pending. The assessing officer on the basis of order of his predecessor disallowed such expenses. The ld. CIT(A) on the prayer of assessee that in the event of success in appeal of A.Y. 2002-03, the deduction allowed in this year will be offer…

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

…iness. 6.1 I have found that this issue is squarely covered by the decision of the Apex Court in the case of Madras Industrial Investment Corporation Ltd Vs Commissioner Of Income Tax, Tamil Nadu I, Madras (Supreme Court of India) in the Appeal Number: (1997) 225 ITR 802 (SC) dated 04/04/1997. The relevant part of this order is reproduced under: as "Thus, expenditure is not necessarily confined to the money which has been actually paid out. It covers a liability which has accrued or which has been incurred although it may have to be discharged at a future date. However, a contingent liability which may have to be…

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2) , BENGALURU

ITA 26/BANG/2024[2018-19]Status: DisposedITAT Bangalore31 Oct 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

…instant case, the appellant has capitalized the amounts paid and claimed depreciation on the same which is also in accordance with the reasoning of the decision of the Hon'ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT (1997) 225 ITR 802 (SC). Therefore, the appellant is entitled to claim the amount paid as either revenue and claim in the first year totally or capital and claim depreciation or amortisation. Copy of the decisions in the case of Taparia Tools and Madras Industrial Investment Corpn. Ltd. are enclosed. dd. The attitude of the revenue is to neither give the same as c…

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2) , BENGALURU

ITA 25/BANG/2024[2017-18]Status: DisposedITAT Bangalore31 Oct 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Respondent: Shri. A. Shankar, Sr. Advocate
Section 132Section 153ASection 234ASection 250

…instant case, the appellant has capitalized the amounts paid and claimed depreciation on the same which is also in accordance with the reasoning of the decision of the Hon'ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT (1997) 225 ITR 802 (SC). Therefore, the appellant is entitled to claim the amount paid as either revenue and claim in the first year totally or capital and claim depreciation or amortisation. Copy of the decisions in the case of Taparia Tools and Madras Industrial Investment Corpn. Ltd. are enclosed. dd. The attitude of the revenue is to neither give the same as c…

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

ITA 24/BANG/2024[2016-17]Status: DisposedITAT Bangalore31 Oct 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

…instant case, the appellant has capitalized the amounts paid and claimed depreciation on the same which is also in accordance with the reasoning of the decision of the Hon’ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT (1997) 225 ITR 802 (SC). Therefore, the appellant is entitled to claim the amount paid as either revenue and claim in the first year totally or capital and claim depreciation or amortisation. Copy of the decisions in the case of Taparia Tools and Madras Industrial Investment Corpn. Ltd. are enclosed. ITA Nos.21 to 26/Bang/2024 Page 33 of 47 dd. The attitude of th…

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX OFFICER, CENTRAL CIRCLE-2(2), BENGALURU

ITA 23/BANG/2024[2015-16]Status: DisposedITAT Bangalore31 Oct 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

Section 153ASection 234ASection 250

…instant case, the appellant has capitalized the amounts paid and claimed depreciation on the same which is also in accordance with the reasoning of the decision of the Hon'ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT (1997) 225 ITR 802 (SC). Therefore, the appellant is entitled to claim the amount paid as either revenue and claim in the first year totally or capital and claim depreciation or amortisation. Copy of the decisions in the case of Taparia Tools and Madras Industrial Investment Corpn. Ltd. are enclosed. Page 32 of 47 ITA Nos.21 to 26/Bang/2024 dd. The attitude of the…

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

ITA 22/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Oct 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

…instant case, the appellant has capitalized the amounts paid and claimed depreciation on the same which is also in accordance with the reasoning of the decision of the Hon’ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT (1997) 225 ITR 802 (SC). Therefore, the appellant is entitled to claim the amount paid as either revenue and claim in the first year totally or capital and claim depreciation or amortisation. Copy of the decisions in the case of Taparia Tools and Madras Industrial Investment Corpn. Ltd. are enclosed. ITA Nos.21 to 26/Bang/2024 Page 33 of 47 dd. The attitude of th…

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

ITA 21/BANG/2024[2013-14]Status: DisposedITAT Bangalore31 Oct 2025AY 2013-14

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

…instant case, the appellant has capitalized the amounts paid and claimed depreciation on the same which is also in accordance with the reasoning of the decision of the Hon’ble Supreme Court in the case of Madras Industrial Investment Corpn. Ltd. v. CIT (1997) 225 ITR 802 (SC). Therefore, the appellant is entitled to claim the amount paid as either revenue and claim in the first year totally or capital and claim depreciation or amortisation. Copy of the decisions in the case of Taparia Tools and Madras Industrial Investment Corpn. Ltd. are enclosed. ITA Nos.21 to 26/Bang/2024 Page 33 of 47 dd. The attitude of th…

FAIRBRIDGE CAPITAL PRIVATE LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, MUMBAI - 6, MUMBAI, MAHARASHTRA

In the result, appeal of the assessee is allowed

ITA 3626/MUM/2025[2020-21]Status: DisposedITAT Mumbai24 Oct 2025AY 2020-21
For Appellant: \nMs. Chandni Shah a/w Mr. Hardik Nirmal andFor Respondent: \nShri Vivek Perampurna, CIT, D/R [virtually
Section 143(3)Section 263

…ons\nwhere the courts have held that it is permissible to defer/spread over an expenditure\nclaim over more than one accounting period to match the corresponding benefit\nderived over such period:\n• Madras Industrial Investment Corporation Ltd. v. CIT [1997] 225 ITR 802 (SC)\n• CIT v. Shree Rajasthan Syntex Limited 2004) 186 CIR 59 (Rajasthan)\n• CIT v. S.M. Holding and Finance P. Ltd. [2003] 264 ITR 370 (Bombay)\n2.11 In light of the above, it is submitted that the expenditure incurred by the\nCompany on share-based. payments of INR 63,280,228 should be allowable as\ndeduction under Section 37(1) of the Act\n5.…

DCIT, CIRCLE - 19(1), DELHI vs. PUNJAB NATIONAL BANK (EARLIER KNOWN AS ORIENTAL BANK OF COMMERCE), DELHI

Appeal is dismissed in above terms

ITA 3161/DEL/2024[2017-18]Status: DisposedITAT Delhi24 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraassessment Year: 2017-18 Dcit, Vs. Punjab National Bank (Earlier Circle-19(1), Know As Oriental Bank Of Delhi Commerce), Harsha Bhawan, E Block, Connaught Place, Delhi Pan: Aaaco0191M (Appellant) (Respondent) Assessee By Sh. K.V.S.R. Krishana, Ca Department By Sh. Dayainder Singh Sidhu, Cit(Dr)

Section 143(3)Section 14ASection 36(1)Section 36(2)(v)

…than 180 days allowed by the Assessing Officer that the erection and fixtures mentioned above have longer life than one year and of enduring benefit to the assessee company as held by the Hon'ble Apex Court in the case of Madras Industrial Corporation vs. CIT 225 ITR 802." 4. Whether on the facts and under the circumstances of the case, the Ld. CIT (A) has erred in law and the facts in deleting the disallowance of Rs.570.86 Cr on account of inter office adjustment made by the Assessing Officer of the Income-tax Act, 1961." 5. Whether on the facts and under the circumstances of the case, the Ld. CIT(A) has erred i…

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Madras Industrial Investment Corporation Ltd. v. CIT (225 ITR 802) — Cited in 568 Judgments | BharatTax