Punjab State Industrial Development Corporation Ltd. v. CIT

225 ITR 792Supreme Court of India1997#619 most cited

What is Punjab State Industrial Development Corporation Ltd. v. CIT authority for?

Expenditure incurred for increasing a company's share capital, such as expenses related to issuing shares or an initial public offering (IPO), is capital expenditure. Such expenses are not allowable as a revenue deduction under Section 37, even if they incidentally benefit the business, because they result in an increase in capital.

158

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2006 to 2026.

Also referred to as

Punjab State Industrial Development Corporation Ltd. v. CIT · 225 ITR 792 · Section 37 · Section 37(1) · capital expenditure · revenue expenditure · issue of shares · IPO expenses · increase in share capital · allowability of deduction · business expenditure

Also reported as

93 Taxmann 5

Sections most often in play

Section 37(1)Section 143(3)Section 14ASection 35DSection 10BSection 43(5)Section 37Section 36(1)(iii)

Issues it is cited on

section 35denduring benefitsection 35revenue expendituredisallowance under section 14acapital expenditureput to usesection 45fair market valuemercantile system of accountingsection 37(1)section 37

Judgments citing Punjab State Industrial Development Corporation Ltd. v. CIT

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

…umstances of the case. 2 That both CIT(A) & AO have erred in law and on facts in treating, IPO expenses amounting to Rs. 1,68,30,430/- as capital expenditure arbitrarily and without any justification.It is contended that the ratio of the judgements in case of 225 ITR 792 and 225 ITR 798 are not applicable to the appellant's case. 3 The above grounds of appeal are independent and without prejudice to one and another. ITA No.- 3626/Del/2015(A.Y. 2010-11) Assessee’s appeal 1 That the orders passed by lower authorities are bad in law and against the facts & circumstances of the case. 2 That both CIT(A) & AO have erre…

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

ITA 3774/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 14ASection 43(5)

…umstances of the case. 2. That both CIT(A) & AO have erred in law and on facts in treating, IPO expenses amounting to Rs.1,68,30,430/- as capital expenditure arbitrarily and without any justification.It is contended that the ratio of the judgements in case of 225 ITR 792 and 225 ITR 798 are not applicable to the appellant's case. 3. The above grounds of appeal are independent and without prejudice to one and another. ITA No.- 3626/Del/2015(A.Y. 2010-11) Assessee's appeal 1. That the orders passed by lower authorities are bad in law and against the facts & circumstances of the case. 2. That both CIT(A) & AO have e…

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

…umstances of the case. 2 That both CIT(A) & AO have erred in law and on facts in treating, IPO expenses amounting to Rs. 1,68,30,430/- as capital expenditure arbitrarily and without any justification.It is contended that the ratio of the judgements in case of 225 ITR 792 and 225 ITR 798 are not applicable to the appellant's case. 3 The above grounds of appeal are independent and without prejudice to one and another. ITA No.- 3626/Del/2015(A.Y. 2010-11) Assessee’s appeal 1 That the orders passed by lower authorities are bad in law and against the facts & circumstances of the case. 2 That both CIT(A) & AO have erre…

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

…umstances of the case. 2 That both CIT(A) & AO have erred in law and on facts in treating, IPO expenses amounting to Rs. 1,68,30,430/- as capital expenditure arbitrarily and without any justification.It is contended that the ratio of the judgements in case of 225 ITR 792 and 225 ITR 798 are not applicable to the appellant's case. 3 The above grounds of appeal are independent and without prejudice to one and another. ITA No.- 3626/Del/2015(A.Y. 2010-11) Assessee’s appeal 1 That the orders passed by lower authorities are bad in law and against the facts & circumstances of the case. 2 That both CIT(A) & AO have erre…

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

…umstances of the case. 2 That both CIT(A) & AO have erred in law and on facts in treating, IPO expenses amounting to Rs. 1,68,30,430/- as capital expenditure arbitrarily and without any justification.It is contended that the ratio of the judgements in case of 225 ITR 792 and 225 ITR 798 are not applicable to the appellant's case. 3 The above grounds of appeal are independent and without prejudice to one and another. ITA No.- 3626/Del/2015(A.Y. 2010-11) Assessee’s appeal 1 That the orders passed by lower authorities are bad in law and against the facts & circumstances of the case. 2 That both CIT(A) & AO have erre…

ZARAH RAFIQUE MALIK,MUMBAI vs. ITO (INT TAX) WARD-3(2)(1), MUMBAI

ITA 5159/MUM/2025[2022-23]Status: DisposedITAT Mumbai10 Mar 2026AY 2022-23

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri Vikram Singh Yadav, Hon’Blezarah Rafique Malik Income Tax Officer, (Int.Tax) B/1703, Vivarea Condominium, Ward- 3(2)(1), Mumbai Vs. Sane Guruji Marg, Jacob Circle, Mahalaxmi East Mumbai – 400 011 Pan : Adcpm8960G (Appellant) (Respondent)

For Appellant: Shri K Gopal, Adv. & Shri Oom KandalkarFor Respondent: Shri Krishna Kumar, Sr. DR
Section 120(4)(b)Section 127Section 143(2)Section 143(3)Section 144BSection 153(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “I”, MUMBAI Before Justice (Retd.) C V Bhadang, Hon’ble President & Shri Vikram Singh Yadav, Hon’ble Accountant Member Zarah Rafique Malik Income Tax Officer, (INT.TAX) B/1703, Vivarea Condominium, Ward- 3(2)(1), Mumbai Vs. Sane Guruji Marg, Jacob Circle, Mahalaxmi East Mumbai – 400 011 PAN : ADCPM8960G (Appellant) (Respondent) Appellant By : Shri K Gopal, Adv. & Shri Oom Kandalkar Respondent By : Shri Krishna Kumar, Sr. DR Date of Hearing : 21.01.2026 Date of Pronouncement: 10.03.2026 O R D E R PER VIKRAM SINGH YADAV, A.M : By this appeal, appellant-assessee…

SRI RAMA AGRI GENETICS (INDIA) PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

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

ITA 1179/HYD/2025[2015-16]Status: DisposedITAT Hyderabad21 Jan 2026AY 2015-16
Section 142(1)Section 143(3)Section 201Section 263Section 36(1)(iii)Section 36(1)(va)Section 41(1)Section 68

…the nature of revenue expenditure and it should be allowed. The A.O., after considering the submissions of the assessee and also by following the decision of Hon'ble Supreme Court in the case of Punjab State Industrial Development Corporation Limited Vs. CIT, 225 ITR 792 and Brooke Bond India Limited Vs. CIT, 225 ITR 798, disallowed ROC charges paid of Rs. 5,72,481/- on the ground that, the expenditure incurred towards increase in authorised capital of the assessee company is capital in nature and the same cannot be allowed under Section 37(1) of the Income-tax Act, 1961. 9. On appeal, the Ld. CIT(A) allowed part…

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

…share premium as received is a capital\nreceipt and not its income. ESOP expenses are not relatable the profit and gains\narising or accruing from a business/trade. The Apex Court decision in the case of\nPunjab State Industrial Development Corp. Ltd. (1997) 225 ITR 792 (SC) and Brooke\nBond India Ltd. (1997) 225 ITR 798 (SC) have held that expenditure resulting in\n\"increase in capital\" is not allowable deduction even if such expenditure may\nincidentally help in the business of the company.\nThere is no specific provision for such deduction from section 30 to 36 of the\nIncome Tax Act, 1961. So the residuary…

ADDL CIT LTU, MUMBAI vs. BAJAJ HOLDING & INVESTMENT LTD ( FOREMERLY KNOWN AS BAJAJ AUTO LTD), MUMBAI

In the result, appeal filed by the revenue is dismissed and appeal filed by the assessee stands partly allowed as indicated hereinabove

ITA 5510/MUM/2012[2007-08]Status: DisposedITAT Mumbai26 Aug 2025AY 2007-08

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

Section 14ASection 80

…was incurred in connection with the issue of shares for increase in share capital. AO made disallowance basing on the apex court judgments in the case of M/s Brooke Bond India Ltd (225 ITR 798)(SC) and M/s Punjab State Industrial Development Corporation Ltd (225 ITR 792)(SC). The CIT (A) confirmed the action of the AO stating that the said expenditure should not be allowed as revenue expenditure. During the proceedings before us, Ld AR for assessee relied on various judgments including the jurisdictional High Court judgment in the case of Maharashtra Ugine and Steel Co Ltd (250 ITR 84) (Bom). After going through…

AGS TRANSACT TECHNOLOGIES LIMITED,MUMBAI vs. DCIT CIRCLE 6(1)(1), AAYAKAR BHAVAN MUMBAI

ITA 4653/MUM/2024[2020-2021]Status: DisposedITAT Mumbai17 Feb 2025AY 2020-2021

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2020-21 Ags Transact Technologies Dcit Circle 6(1)(1), Ltd., Aayakar Bhavan, Vs. 601-602, Trade World, B Wing Mumbai-400020. S.B. Marg, Lower Parel, Mumbai-400013. Pan No. Aaeca 0901 H Appellant Respondent

For Appellant: Mr. Dalpat ShahFor Respondent: 04/12/2024

…d in 225 ITR 798 (SC) of Brook Bond India Ltd. v. CIT reported in 225 ITR of Brook Bond India Ltd. v. CIT reported in 225 ITR and in the case of Punjab State Industrial Development Punjab State Industrial Development and in the case of Corporation Ltd. v. CIT 225 ITR 792 Corporation Ltd. v. CIT 225 ITR 792(SC) and submitted that and submitted that AGS Transact Technologies Ltd AGS Transact Technologies Ltd same falls under the purview of capital expenditure. The Ld. CIT(A) same falls under the purview of capital expenditure. The Ld. CIT(A) same falls under the purview of capital expenditure. The Ld. CIT(A) furthe…

FINOVA CAPITAL PRIVATE LIMITED,JAIPUR vs. PCIT-1, JAIPUR, JAIPUR

ITA 149/JPR/2024[2018-19]Status: HeardITAT Jaipur13 Dec 2024AY 2018-19

Bench: The Date Of Hearing.”

For Appellant: Sh. Rohan Sogani, CA &For Respondent: MS Alka Gautam, CIT
Section 263

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, vk;dj vihy la-@ITA No. 149/JP/2024 fu/kZkj.k o"kZ@Assessment Years : 2018-19 cuke Finova Capital Private Limited PCIT-1, 702, 7th Floor Unique Aspire, Vs. Jaipur, Jaipur Cosmo Colony, Vaishali Nagar, Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AACCF 6521 A vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Rohan Sogani, CA &…

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMA LABORATORIES LTD.,, MUMBAI

In the result, the Department’s appeal is partly allowed

ITA 741/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad09 Oct 2024AY 2015-16

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 36(1)(va)Section 37(1)Section 80Section 80I

…O at para 19 of the assessment order has observed that RoC filing fees paid for increase in share capital is capital expenditure in view of decisions of Brooke Bond India Ltd Vs CIT [225 ITR 798] and Punjab State Industrial Development Corporation Ltd Vs CIT [225 ITR 792]. The above addition was upheld by Ld. CIT(A) mainly relying on the findings of the Ld. AO in his order. 12.1. Ld. Senior Counsel appearing for the assessee fairly admitted that this issue is held against the assessee in its own case by the Co-ordinate Bench in ITA Nos.1464 & 1465/Ahd/2018 relating to the Asst. Years 2013-14 & 2014-15. 13. We ha…

SUN PHARMA LABORATORIES LTD.,,MUMBAI vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA

In the result, the Department’s appeal is partly allowed

ITA 712/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad09 Oct 2024AY 2015-16

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 36(1)(va)Section 37(1)Section 80Section 80I

…O at para 19 of the assessment order has observed that RoC filing fees paid for increase in share capital is capital expenditure in view of decisions of Brooke Bond India Ltd Vs CIT [225 ITR 798] and Punjab State Industrial Development Corporation Ltd Vs CIT [225 ITR 792]. The above addition was upheld by Ld. CIT(A) mainly relying on the findings of the Ld. AO in his order. 12.1. Ld. Senior Counsel appearing for the assessee fairly admitted that this issue is held against the assessee in its own case by the Co-ordinate Bench in ITA Nos.1464 & 1465/Ahd/2018 relating to the Asst. Years 2013-14 & 2014-15. 13. We ha…

SATYANARAYAN HOLDINGS PVT. LTD.,KOLKATA vs. ITO, WARD-5(2), KOLKATA

ITA 444/KOL/2024[2012-13]Status: DisposedITAT Kolkata26 Sept 2024AY 2012-13

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.444/Kol/2024 Assessment Year: 2012-13

Section 143(1)Section 249Section 250Section 253Section 3Section 5

…settled proposition of law that any expenditure incurred for the expansion of the capital base of a company is to be treated as a capital expenditure as has been held by the Hon'ble Supreme Court in the case of Punjab State Industrial Corporation Ltd. Vs CIT 225 ITR 792 and in the case of Brooke Bond India Ltd. VS CIT. In the case of KapurchandShrimal Vs CIT 131 ITR 451, it was held that an appellate authority has the jurisdiction as well as the duty to correct all errors in the proceedings under appeal and to issue, if necessary, appropriate directions to the authority against whose decision the appeal was pref…

M/S.COCHIN SHIPYARD LTD,KOCHI vs. DCIT CORPORATE CIRCLE 1(1), KOCHI, KOCHI

In the result, the assessee’s appeal is dismissed

ITA 654/COCH/2022[2017-2018]Status: DisposedITAT Cochin28 Mar 2024AY 2017-2018

Bench: Shri Sanjay Arora & Shri Manomohan Dascochin Shipyard Ltd. Dy. Cit, Corporate Circle 1(1) Administrative Building C.R. Building, I.S. Press Road Shipyard Premises Kochi 682018 Vs. Perumanoor P.O. Kochi 682015 [Pan:Aaacc6905B] (Appellant) (Respondent)

For Appellant: Shri Radhesh L. Bhat, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 263Section 32(1)(iia)

…ible u/s. 37(1) of the Act. Some of the decisions that come readily to mind, and which may therefore require being visited and examined for their applicability, i.e., vis-à-vis their ratio, are PSIDC v. CIT [1997] 3 | P a g e Cochin Shipyard Ltd. v. Dy. CIT 225 ITR 792 (SC); Brook Bond (I) Ltd. v. CIT [1997] 225 ITR 798 (SC); CIT v. Tisco Ltd. [1998] 231 ITR 285 (SC); India Cements Ltd. v. CIT [1966] 60 ITR 52 (SC). 3.4 The issue qua the second aspect flagged by the ld. Pr.CIT is the retrospectivity or otherwise of the amendment to s. 32(1)(iia) of the Act. Even as an amendment is, otherwise than where express…

DCIT RG. - 3(1), MUMBAI vs. M/S. BAJAJ AUTO LTD., MUMBAI

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

ITA 4372/MUM/2005[2001-2002]Status: DisposedITAT Mumbai23 Feb 2024AY 2001-2002

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Bajaj Auto Limited V. Dcit – Range – 3(1) Bajaj Bhavan, 226-Nariman Point 6Th Floor, Aayakar Bhavan Mumbai – 400021 M.K. Road, Mumbai - 400020 Pan : Aaacb3370K (Appellant) (Respondent) Dcit – Range – 3(1) V. M/S. Bajaj Auto Limited Room No. 623, 6Th Floor Bajaj Bhavan, 226-Nariman Point Mumbai – 400021 Aayakar Bhavan M.K. Road, Mumbai - 400020 Pan : Aaacb3370K (Appellant) (Respondent) Assessee Represented By : Ms. Vasanti Patel& Shri Kirit Kamdar Department Represented By : Shri Ankush Kapoor

Section 143(4)(b)Section 234Section 35Section 35DSection 37(1)Section 40

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F”, MUMBAI BEFORE SHRI ABY T VARKEY, HON’BLE JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER M/s. Bajaj Auto Limited v. DCIT – Range – 3(1) Bajaj Bhavan, 226-Nariman Point 6th Floor, Aayakar Bhavan Mumbai – 400021 M.K. Road, Mumbai - 400020 PAN : AAACB3370K (Appellant) (Respondent) DCIT – Range – 3(1) v. M/s. Bajaj Auto Limited Room No. 623, 6th Floor Bajaj Bhavan, 226-Nariman Point Mumbai – 400021 Aayakar Bhavan M.K. Road, Mumbai - 400020 PAN : AAACB3370K (Appellant) (Respondent) Assessee Represented by : Ms. Vasanti Patel& Shri Kirit Kamdar…

M/S. BAJAJ AUTO LTD.,MUMBAI vs. DCIT RG. - 3(1), MUMBAI

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

ITA 4236/MUM/2005[2001-2002]Status: DisposedITAT Mumbai23 Feb 2024AY 2001-2002

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Bajaj Auto Limited V. Dcit – Range – 3(1) Bajaj Bhavan, 226-Nariman Point 6Th Floor, Aayakar Bhavan Mumbai – 400021 M.K. Road, Mumbai - 400020 Pan : Aaacb3370K (Appellant) (Respondent) Dcit – Range – 3(1) V. M/S. Bajaj Auto Limited Room No. 623, 6Th Floor Bajaj Bhavan, 226-Nariman Point Mumbai – 400021 Aayakar Bhavan M.K. Road, Mumbai - 400020 Pan : Aaacb3370K (Appellant) (Respondent) Assessee Represented By : Ms. Vasanti Patel& Shri Kirit Kamdar Department Represented By : Shri Ankush Kapoor

Section 143(4)(b)Section 234Section 35Section 35DSection 37(1)Section 40

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F”, MUMBAI BEFORE SHRI ABY T VARKEY, HON’BLE JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER M/s. Bajaj Auto Limited v. DCIT – Range – 3(1) Bajaj Bhavan, 226-Nariman Point 6th Floor, Aayakar Bhavan Mumbai – 400021 M.K. Road, Mumbai - 400020 PAN : AAACB3370K (Appellant) (Respondent) DCIT – Range – 3(1) v. M/s. Bajaj Auto Limited Room No. 623, 6th Floor Bajaj Bhavan, 226-Nariman Point Mumbai – 400021 Aayakar Bhavan M.K. Road, Mumbai - 400020 PAN : AAACB3370K (Appellant) (Respondent) Assessee Represented by : Ms. Vasanti Patel& Shri Kirit Kamdar…

M/S DHARANI DEVELOPERS PRIVATE LIMITED,ALWARPET, CHENNAI vs. ACIT, COMPANY CIRCLE 1(4), NUNGAMBAKKAM CHENNAI

ITA 401/CHNY/2023[2017-18]Status: DisposedITAT Chennai18 Jan 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.397, 398, 399, 400 & 401/Chny/2023 Assessment Years: 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18 M/S. Dharani Developers Private Vs. The Asst/Deputy Commissioner Of Limited, No. 1, Venus Colony Ii Street, Income Tax, Corporate Circle 1(1), Alwarpet, Chennai 600 018. 121, Mahatma Gandhi Road, [Pan:Aabcd6222D] Nungambakkam, Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ramakrishnan, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.01.2024 घोषणा की तारीख /Date Of Pronouncement : 18.01.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, All Dated 31.01.2023 Relevant To The Assessment Years 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Property Development & Filed Its Return Of Income For The Assessment Years Under Appeal. The First Ground Raised By The Assessee

For Appellant: Shri K. Ramakrishnan, CAFor Respondent: Shri D. Hema Bhupal, JCIT

…has held that this expenditure is not allowable a it is capital in nature and accordingly disallowed ₹.3,30,000/- and brought to tax. On appeal, by following the decision in the case of Punjab State Industrial Corporation v. 9 I.T.A. Nos.397-401/Chny/23 CIT 225 ITR 792 (SC), the ld. CIT(A) confirmed the addition made by the Assessing Officer. 8.1 Before us, the ld. Counsel for the assessee has submitted that the fee was paid in relation to statutory compliance for increase in authorized share capital. The assessee raised more resources by way of capital for the purpose of increasing/scaling up the operations/b…

M/S DHARANI DEVELOPERS PRIVATE LIMITED,ALWARPET, CHENNAI vs. ACIT, COMPANY CIRCLE 1(4), NUNGAMBAKKAM CHENNAI

ITA 400/CHNY/2023[2016-17]Status: DisposedITAT Chennai18 Jan 2024AY 2016-17

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.397, 398, 399, 400 & 401/Chny/2023 Assessment Years: 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18 M/S. Dharani Developers Private Vs. The Asst/Deputy Commissioner Of Limited, No. 1, Venus Colony Ii Street, Income Tax, Corporate Circle 1(1), Alwarpet, Chennai 600 018. 121, Mahatma Gandhi Road, [Pan:Aabcd6222D] Nungambakkam, Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ramakrishnan, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.01.2024 घोषणा की तारीख /Date Of Pronouncement : 18.01.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, All Dated 31.01.2023 Relevant To The Assessment Years 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Property Development & Filed Its Return Of Income For The Assessment Years Under Appeal. The First Ground Raised By The Assessee

For Appellant: Shri K. Ramakrishnan, CAFor Respondent: Shri D. Hema Bhupal, JCIT

…has held that this expenditure is not allowable a it is capital in nature and accordingly disallowed ₹.3,30,000/- and brought to tax. On appeal, by following the decision in the case of Punjab State Industrial Corporation v. 9 I.T.A. Nos.397-401/Chny/23 CIT 225 ITR 792 (SC), the ld. CIT(A) confirmed the addition made by the Assessing Officer. 8.1 Before us, the ld. Counsel for the assessee has submitted that the fee was paid in relation to statutory compliance for increase in authorized share capital. The assessee raised more resources by way of capital for the purpose of increasing/scaling up the operations/b…

M/S DHARANI DEVELOPERS PRIVATE LIMITED,ALWARPET, CHENNAI vs. ACIT, COMPANY CIRCLE 1(4), NUNGAMBAKKAM CHENNAI

ITA 399/CHNY/2023[2013-14]Status: DisposedITAT Chennai18 Jan 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.397, 398, 399, 400 & 401/Chny/2023 Assessment Years: 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18 M/S. Dharani Developers Private Vs. The Asst/Deputy Commissioner Of Limited, No. 1, Venus Colony Ii Street, Income Tax, Corporate Circle 1(1), Alwarpet, Chennai 600 018. 121, Mahatma Gandhi Road, [Pan:Aabcd6222D] Nungambakkam, Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ramakrishnan, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.01.2024 घोषणा की तारीख /Date Of Pronouncement : 18.01.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, All Dated 31.01.2023 Relevant To The Assessment Years 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Property Development & Filed Its Return Of Income For The Assessment Years Under Appeal. The First Ground Raised By The Assessee

For Appellant: Shri K. Ramakrishnan, CAFor Respondent: Shri D. Hema Bhupal, JCIT

…has held that this expenditure is not allowable a it is capital in nature and accordingly disallowed ₹.3,30,000/- and brought to tax. On appeal, by following the decision in the case of Punjab State Industrial Corporation v. 9 I.T.A. Nos.397-401/Chny/23 CIT 225 ITR 792 (SC), the ld. CIT(A) confirmed the addition made by the Assessing Officer. 8.1 Before us, the ld. Counsel for the assessee has submitted that the fee was paid in relation to statutory compliance for increase in authorized share capital. The assessee raised more resources by way of capital for the purpose of increasing/scaling up the operations/b…

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