Orchid Chemicals & Pharmaceuticals v. ACIT

124 TTJ 531Income Tax Appellate Tribunal#7225 most cited

What is Orchid Chemicals & Pharmaceuticals v. ACIT authority for?

Non-compete fees paid by a taxpayer can be treated as deferred revenue expenditure, deductible over a period of 10 years.

15

judgments rely on this decision, according to BharatTax’s citation analysis of 366,315 Indian tax judgments — from 2019 to 2025.

Also referred to as

Orchid Chemicals & Pharmaceuticals v. ACIT · deferred revenue expenditure · non-compete fees · deduction · ITAT Chennai

Issues it is cited on

section 23aretention moneysection 145(1)section 211section 115baasection 28(iv)section 145(2)project completion methodsection 43csection 35dpercentage completion methodsection 129

Judgments citing Orchid Chemicals & Pharmaceuticals v. ACIT

DCIT, Circle-7(1), Delhi vs. Dlf Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 715/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…an order u/s 263 setting aside the assessment made u/s 143(3) on the ground that the AO wrongly accepted the Project Completion Method (PCM) as against Percentage of Completion Method which should have been applied. In the case of ITO vs Sify E-Learning Ltd.: 124 TTJ 531, decided by ITAT Chennai (refer Page 540-551 of Paper Book Vol-2), the assessee engaged in development of software while following project completion method raised invoices on basis of payment milestones while revenue earned by the assessee from software and consultancy services was recognized on delivery of goods/services. The said method was in…

DCIT, Circle-7(1), Delhi vs. Dlf Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 714/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…an order u/s 263 setting aside the assessment made u/s 143(3) on the ground that the AO wrongly accepted the Project Completion Method (PCM) as against Percentage of Completion Method which should have been applied. In the case of ITO vs Sify E-Learning Ltd.: 124 TTJ 531, decided by ITAT Chennai (refer Page 540-551 of Paper Book Vol-2), the assessee engaged in development of software while following project completion method raised invoices on basis of payment milestones while revenue earned by the assessee from software and consultancy services was recognized on delivery of goods/services. The said method was in…

DCIT, Circle-7(1), Delhi vs. Dlf Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 713/DEL/2024[2019-20]Status: DisposedITAT Delhi30 Oct 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…an order u/s 263 setting aside the assessment made u/s 143(3) on the ground that the AO wrongly accepted the Project Completion Method (PCM) as against Percentage of Completion Method which should have been applied. In the case of ITO vs Sify E-Learning Ltd.: 124 TTJ 531, decided by ITAT Chennai (refer Page 540-551 of Paper Book Vol-2), the assessee engaged in development of software while following project completion method raised invoices on basis of payment milestones while revenue earned by the assessee from software and consultancy services was recognized on delivery of goods/services. The said method was in…

Dlf Limited, Delhi vs. National Faceless Assessment Centre, Delhi

In the result, appeal of the Revenue is dismissed

ITA 677/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…an order u/s 263 setting aside the assessment made u/s 143(3) on the ground that the AO wrongly accepted the Project Completion Method (PCM) as against Percentage of Completion Method which should have been applied. In the case of ITO vs Sify E-Learning Ltd.: 124 TTJ 531, decided by ITAT Chennai (refer Page 540-551 of Paper Book Vol-2), the assessee engaged in development of software while following project completion method raised invoices on basis of payment milestones while revenue earned by the assessee from software and consultancy services was recognized on delivery of goods/services. The said method was in…

Dlf Limited, Delhi vs. National Faceless Assessment Centre, Delhi

In the result, appeal of the Revenue is dismissed

ITA 676/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…an order u/s 263 setting aside the assessment made u/s 143(3) on the ground that the AO wrongly accepted the Project Completion Method (PCM) as against Percentage of Completion Method which should have been applied. In the case of ITO vs Sify E-Learning Ltd.: 124 TTJ 531, decided by ITAT Chennai (refer Page 540-551 of Paper Book Vol-2), the assessee engaged in development of software while following project completion method raised invoices on basis of payment milestones while revenue earned by the assessee from software and consultancy services was recognized on delivery of goods/services. The said method was in…

ACIT Ltu-2, Chennai vs. Chemplast Sanmar Limited, Chennai

In the result, the appeal of the assessee in I

ITA 2963/CHNY/2017[2014-15]Status: DisposedITAT Chennai04 Dec 2019AY 2014-15

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Mr. R. Vijayaraghavan, AdvocateFor Respondent: Mr. M. Srinivasa Rao, JCIT

…ed as deferred revenue expenditure was disallowed by the Assessing Officer. By considering the decisions of the Chennai Benches of the Tribunal in the case of Orchid Chemicals & Pharmaceuticals v. ACIT 137 TTJ 373 and also in the case of ITO v. Seafil Leasing 124 TTJ 531, the ld. CIT(A) directed the Assessing Officer to treat the non-compete fees paid as deferred revenue expenditure and allow 1/10th of the expenditure as deduction for every year by observing as under: “4.2 I have considered various submissions made by the appellant during the appeal proceedings. In similar circumstances, there is a decision of Ho…

ACIT Ltu-2, Chennai vs. Chemplast Sanmar Limited, Chennai

In the result, the appeal of the assessee in I

ITA 2962/CHNY/2017[2013-14]Status: DisposedITAT Chennai04 Dec 2019AY 2013-14

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Mr. R. Vijayaraghavan, AdvocateFor Respondent: Mr. M. Srinivasa Rao, JCIT

…ed as deferred revenue expenditure was disallowed by the Assessing Officer. By considering the decisions of the Chennai Benches of the Tribunal in the case of Orchid Chemicals & Pharmaceuticals v. ACIT 137 TTJ 373 and also in the case of ITO v. Seafil Leasing 124 TTJ 531, the ld. CIT(A) directed the Assessing Officer to treat the non-compete fees paid as deferred revenue expenditure and allow 1/10th of the expenditure as deduction for every year by observing as under: “4.2 I have considered various submissions made by the appellant during the appeal proceedings. In similar circumstances, there is a decision of Ho…

ACIT Ltu-2, Chennai vs. Chemplast Sanmar Limited, Chennai

In the result, the appeal of the assessee in I

ITA 2961/CHNY/2017[2012-13]Status: DisposedITAT Chennai04 Dec 2019AY 2012-13

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Mr. R. Vijayaraghavan, AdvocateFor Respondent: Mr. M. Srinivasa Rao, JCIT

…ed as deferred revenue expenditure was disallowed by the Assessing Officer. By considering the decisions of the Chennai Benches of the Tribunal in the case of Orchid Chemicals & Pharmaceuticals v. ACIT 137 TTJ 373 and also in the case of ITO v. Seafil Leasing 124 TTJ 531, the ld. CIT(A) directed the Assessing Officer to treat the non-compete fees paid as deferred revenue expenditure and allow 1/10th of the expenditure as deduction for every year by observing as under: “4.2 I have considered various submissions made by the appellant during the appeal proceedings. In similar circumstances, there is a decision of Ho…

ACIT Ltu-2, Chennai vs. Chemplast Sanmar Limited, Chennai

In the result, the appeal of the assessee in I

ITA 2960/CHNY/2017[2011-12]Status: DisposedITAT Chennai04 Dec 2019AY 2011-12

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Mr. R. Vijayaraghavan, AdvocateFor Respondent: Mr. M. Srinivasa Rao, JCIT

…ed as deferred revenue expenditure was disallowed by the Assessing Officer. By considering the decisions of the Chennai Benches of the Tribunal in the case of Orchid Chemicals & Pharmaceuticals v. ACIT 137 TTJ 373 and also in the case of ITO v. Seafil Leasing 124 TTJ 531, the ld. CIT(A) directed the Assessing Officer to treat the non-compete fees paid as deferred revenue expenditure and allow 1/10th of the expenditure as deduction for every year by observing as under: “4.2 I have considered various submissions made by the appellant during the appeal proceedings. In similar circumstances, there is a decision of Ho…

ACIT Ltu-2, Chennai vs. Chemplast Sanmar Limited, Chennai

In the result, the appeal of the assessee in I

ITA 2958/CHNY/2017[2009-10]Status: DisposedITAT Chennai04 Dec 2019AY 2009-10

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Mr. R. Vijayaraghavan, AdvocateFor Respondent: Mr. M. Srinivasa Rao, JCIT

…ed as deferred revenue expenditure was disallowed by the Assessing Officer. By considering the decisions of the Chennai Benches of the Tribunal in the case of Orchid Chemicals & Pharmaceuticals v. ACIT 137 TTJ 373 and also in the case of ITO v. Seafil Leasing 124 TTJ 531, the ld. CIT(A) directed the Assessing Officer to treat the non-compete fees paid as deferred revenue expenditure and allow 1/10th of the expenditure as deduction for every year by observing as under: “4.2 I have considered various submissions made by the appellant during the appeal proceedings. In similar circumstances, there is a decision of Ho…

ACIT Ltu-2, Chennai vs. Chemplast Sanmar Limited, Chennai

In the result, the appeal of the assessee in I

ITA 2957/CHNY/2017[2008-09]Status: DisposedITAT Chennai04 Dec 2019AY 2008-09

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Mr. R. Vijayaraghavan, AdvocateFor Respondent: Mr. M. Srinivasa Rao, JCIT

…ed as deferred revenue expenditure was disallowed by the Assessing Officer. By considering the decisions of the Chennai Benches of the Tribunal in the case of Orchid Chemicals & Pharmaceuticals v. ACIT 137 TTJ 373 and also in the case of ITO v. Seafil Leasing 124 TTJ 531, the ld. CIT(A) directed the Assessing Officer to treat the non-compete fees paid as deferred revenue expenditure and allow 1/10th of the expenditure as deduction for every year by observing as under: “4.2 I have considered various submissions made by the appellant during the appeal proceedings. In similar circumstances, there is a decision of Ho…

Chemplast Sanmar Limited, Chennai vs. DCIT Ltu, Chennai

In the result, the appeal of the assessee in I

ITA 2810/CHNY/2017[2013-14]Status: DisposedITAT Chennai04 Dec 2019AY 2013-14

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Mr. R. Vijayaraghavan, AdvocateFor Respondent: Mr. M. Srinivasa Rao, JCIT

…ed as deferred revenue expenditure was disallowed by the Assessing Officer. By considering the decisions of the Chennai Benches of the Tribunal in the case of Orchid Chemicals & Pharmaceuticals v. ACIT 137 TTJ 373 and also in the case of ITO v. Seafil Leasing 124 TTJ 531, the ld. CIT(A) directed the Assessing Officer to treat the non-compete fees paid as deferred revenue expenditure and allow 1/10th of the expenditure as deduction for every year by observing as under: “4.2 I have considered various submissions made by the appellant during the appeal proceedings. In similar circumstances, there is a decision of Ho…

Chemplast Sanmar Limited, Chennai vs. DCIT Ltu, Chennai

In the result, the appeal of the assessee in I

ITA 2809/CHNY/2017[2012-13]Status: DisposedITAT Chennai04 Dec 2019AY 2012-13

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Mr. R. Vijayaraghavan, AdvocateFor Respondent: Mr. M. Srinivasa Rao, JCIT

…ed as deferred revenue expenditure was disallowed by the Assessing Officer. By considering the decisions of the Chennai Benches of the Tribunal in the case of Orchid Chemicals & Pharmaceuticals v. ACIT 137 TTJ 373 and also in the case of ITO v. Seafil Leasing 124 TTJ 531, the ld. CIT(A) directed the Assessing Officer to treat the non-compete fees paid as deferred revenue expenditure and allow 1/10th of the expenditure as deduction for every year by observing as under: “4.2 I have considered various submissions made by the appellant during the appeal proceedings. In similar circumstances, there is a decision of Ho…

Chemplast Sanmar Limited, Chennai vs. DCIT Ltu, Chennai

In the result, the appeal of the assessee in I

ITA 2808/CHNY/2017[2011-12]Status: DisposedITAT Chennai04 Dec 2019AY 2011-12

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Mr. R. Vijayaraghavan, AdvocateFor Respondent: Mr. M. Srinivasa Rao, JCIT

…ed as deferred revenue expenditure was disallowed by the Assessing Officer. By considering the decisions of the Chennai Benches of the Tribunal in the case of Orchid Chemicals & Pharmaceuticals v. ACIT 137 TTJ 373 and also in the case of ITO v. Seafil Leasing 124 TTJ 531, the ld. CIT(A) directed the Assessing Officer to treat the non-compete fees paid as deferred revenue expenditure and allow 1/10th of the expenditure as deduction for every year by observing as under: “4.2 I have considered various submissions made by the appellant during the appeal proceedings. In similar circumstances, there is a decision of Ho…

Chemplast Sanmar Limited, Chennai vs. DCIT Ltu, Chennai

In the result, the appeal of the assessee in I

ITA 2807/CHNY/2017[2010-11]Status: DisposedITAT Chennai04 Dec 2019AY 2010-11

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Mr. R. Vijayaraghavan, AdvocateFor Respondent: Mr. M. Srinivasa Rao, JCIT

…ed as deferred revenue expenditure was disallowed by the Assessing Officer. By considering the decisions of the Chennai Benches of the Tribunal in the case of Orchid Chemicals & Pharmaceuticals v. ACIT 137 TTJ 373 and also in the case of ITO v. Seafil Leasing 124 TTJ 531, the ld. CIT(A) directed the Assessing Officer to treat the non-compete fees paid as deferred revenue expenditure and allow 1/10th of the expenditure as deduction for every year by observing as under: “4.2 I have considered various submissions made by the appellant during the appeal proceedings. In similar circumstances, there is a decision of Ho…

Orchid Chemicals & Pharmaceuticals v. ACIT (124 TTJ 531) — Cited in 15 Judgments | BharatTax