Sree Meenakshi Mills Ltd. v. Commissioner of Income Tax

31 ITR 28Supreme Court of India1957#745 most cited

What is Sree Meenakshi Mills Ltd. v. Commissioner of Income Tax authority for?

Expenditure incurred for commercial expediency, even without a direct or immediate benefit but indirectly facilitating business, is deductible as laid out wholly and exclusively for trade. The scope of reference jurisdiction under Section 66 is limited to questions of law, allowing challenges to Tribunal findings of fact only if they are perverse, unreasonable, or lack evidence.

137

judgments rely on this decision, according to BharatTax’s citation analysis of 368,382 Indian tax judgments — from 2000 to 2026.

Also referred to as

Sree Meenakshi Mills Ltd v CIT · 31 ITR 28 · Section 37 · commercial expediency · revenue expenditure · wholly and exclusively for business · Section 66 · question of law · question of fact · Tribunal findings · perversity

Sections most often in play

Section 119Section 12ASection 12A(1)(ac)(iii)Section 37Section 80G(5)Section 80G(5)(iii)Section 12AASection 133(6)

Issues it is cited on

section 52(2)section 119(1)section 66section 80g(5)(iii)section 10(23c)section 260commercial expediencysection 80g(5)section 119registration under section 12asection 80grevenue expenditure

Judgments citing Sree Meenakshi Mills Ltd. v. Commissioner of Income Tax

Siddhi Vinayak Shiksha Prasar Evam Samaj Kalyan Samiti, Gwalior vs. CIT(Exemption), Bhopal

In the result, the both the appeals ITA No

ITA 579/AGR/2025[2025-26]Status: DisposedITAT Agra20 Feb 2026AY 2025-26

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 12A(1)(ac)Section 80G(5)(iv)

…cumstances, we are unable to say that the Tribunal committed an error in condoning the delay. 24. On the question of perversity of the decision of the Tribunal we may also refer to the judgment of the Supreme Court in Sree Meenakshi Mills Ltd. vs. CIT (1957) 31 ITR 28 (SC). In that judgment, it was noted that only a question of law can be referred for decision of the Court and the decision of the Tribunal on a question of fact can be challenged only if it is not supported by any evidence, or is unreasonable or perverse. The following pithy observations of T. L. Venkatarama Aiyar, J. speaking for the Court are re…

Siddhi Vinayak Shiksha Prasar Evam Samaj Kalyan Samiti, Gwalior vs. CIT(Extemption), Bhopal

In the result, the both the appeals ITA No

ITA 578/AGR/2025[2025-26]Status: DisposedITAT Agra20 Feb 2026AY 2025-26

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 12A(1)(ac)Section 80G(5)(iv)

…cumstances, we are unable to say that the Tribunal committed an error in condoning the delay. 24. On the question of perversity of the decision of the Tribunal we may also refer to the judgment of the Supreme Court in Sree Meenakshi Mills Ltd. vs. CIT (1957) 31 ITR 28 (SC). In that judgment, it was noted that only a question of law can be referred for decision of the Court and the decision of the Tribunal on a question of fact can be challenged only if it is not supported by any evidence, or is unreasonable or perverse. The following pithy observations of T. L. Venkatarama Aiyar, J. speaking for the Court are re…

Shri Achleshwar Mahadevji Ji Sarvjanik Niyas, Gwalior vs. CIT(E), Bhopal

In the result, the appeal is allowed for statistical purposes

ITA 417/AGR/2025[2025-26]Status: DisposedITAT Agra16 Feb 2026AY 2025-26

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year : 2025-26 Shri Achleshwar Mahadev Ji V Cit (Exemption) Sarvajanik Nyas, Sanatan Bhopal Dharm Mandir Road Gwalior- 474 001 Pan : Aahts1225J (Appellant) (Respondent)

Section 80GSection 80G(5)(iii)

…cumstances, we are unable to say that the Tribunal committed an error in condoning the delay. 24. On the question of perversity of the decision of the Tribunal we may also refer to the judgment of the Supreme Court in Sree Meenakshi Mills Ltd. vs. CIT (1957) 31 ITR 28 (SC). In that judgment, it was noted that only a question of law can be referred for decision of the Court and the decision of the Tribunal on a question of fact can be challenged only if it is not supported by any evidence, or is unreasonable or perverse. The following pithy observations of T. L. Venkatarama Aiyar, J. speaking for the Court are re…

Bhai Daya Singh Ji Bhai Himmat Singh Ji Nishkam Satsang Sabha Through Its Managing Trustee, Ludhiana, Punjab vs. The Commissioner of Income-Tax (Exemptions), Chandigarh

Accordingly. 22. In the combined result, both appeals (ITA No.728 & 732/SRT/2023) are allowed for statistical purposes in above terms

ITA 258/ASR/2025[2025-2026]Status: DisposedITAT Amritsar22 Aug 2025AY 2025-2026

Bench: Sh. Udayan Das Gupta & Sh. Khettra Mohan Roy

Section 80GSection 80G(5)Section 80G(5)(iii)

…itted an error in condoning the delay. 24. On the question of perversity of the decision of the Tribunal we may also refer to the judgment of the Supreme Court in I.T.A. No. 257 & 258/Asr/2025 Assessment Year: N/A 11 Sree Meenakshi Mills Ltd. v. CIT [1957] 31 ITR 28. In that judgment, it was noted that only a question of law can be referred for decision of the Court and the decision of the Tribunal on a question of fact can be challenged only if it is not supported by any evidence, or is unreasonable or perverse. The following pithy observations of T.L. Venkatarama Aiyar, J. speaking for the Court are relevant…

Bhai Daya Singh Ji Bhai Dharam Singh Ji Nishkam Satsang Sabha, Ludhiana vs. The Commissioner of Income-Tax (Exemptions), Chandigarh

Accordingly. 22. In the combined result, both appeals (ITA No.728 & 732/SRT/2023) are allowed for statistical purposes in above terms

ITA 257/ASR/2025[2025-2026]Status: DisposedITAT Amritsar22 Aug 2025AY 2025-2026

Bench: Sh. Udayan Das Gupta & Sh. Khettra Mohan Roy

Section 80GSection 80G(5)Section 80G(5)(iii)

…itted an error in condoning the delay. 24. On the question of perversity of the decision of the Tribunal we may also refer to the judgment of the Supreme Court in I.T.A. No. 257 & 258/Asr/2025 Assessment Year: N/A 11 Sree Meenakshi Mills Ltd. v. CIT [1957] 31 ITR 28. In that judgment, it was noted that only a question of law can be referred for decision of the Court and the decision of the Tribunal on a question of fact can be challenged only if it is not supported by any evidence, or is unreasonable or perverse. The following pithy observations of T.L. Venkatarama Aiyar, J. speaking for the Court are relevant…

Krupa Vilas Gau Seva Trust, Kutch vs. CIT(Exemption), Ahmedabad

ITA 163/RJT/2024[NA]Status: DisposedITAT Rajkot24 Mar 2025

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 162/Rjt/2023 (Assessment Year: Na) (Hybrid Hearing) Krupa Vilas Gau Seva Trust, Vs. Cit(Exemption), Kutch. Ahmedabad. Anjar, Anjar Road, Bhimasar Taluka Anjar, Kutch-370240. स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaetk8746K (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No. 163/Rjt/2023 (Assessment Year: Na) (Hybrid Hearing) Krupa Vilas Gau Seva Trust, Vs. Cit(Exemption), Kutch. Ahmedabad. Anjar, Anjar Road, Bhimasar Taluka Anjar, Kutch-370240. स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaetk8746K (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) निर्धारितीकीओरसे/Assessee By : Shri Kalpesh Doshi, Ar राजस्वकीओरसे/Respondent By : Shri Sanjay Punglia, Cit Dr सुनवाईकीतारीख / Date Of Hearing : 09/01/2025 घोषणाकीतारीख / Date Of Pronouncement : 24/03/2025 1 | Page

For Appellant: Shri Kalpesh Doshi, ARFor Respondent: Shri Sanjay Punglia, CIT DR
Section 12ASection 12A(1)(ac)Section 80G(5)

…ircumstances, we are unable to say that the Tribunal committed an error in condoning the delay. 24. On the question of perversity of the decision of the Tribunal we may also refer to the judgment of the Supreme Court in Sree Meenakshi Mills Ltd. v. CIT [1957] 31 ITR 28. In that judgment, it was noted that only a question of law can be referred for decision of the Court and the decision of the Tribunal on a question of fact can be challenged only if it is not supported by any evidence, or is unreasonable or perverse. The following pithy observations of T.L. Venkatarama Aiyar, J. speaking for the Court are relevant…

Krupa Vilas Gau Seva Trust, Kutch vs. CIT(Exemption), Ahmedabad

Appeals of the assessee are allowed for statistical purposes

ITA 162/RJT/2024[NA]Status: DisposedITAT Rajkot24 Mar 2025

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 162/Rjt/2023 (Assessment Year: Na) (Hybrid Hearing)

For Appellant: Shri Kalpesh Doshi, ARFor Respondent: Shri Sanjay Punglia, CIT DR
Section 12ASection 12A(1)(ac)Section 80G(5)

…ircumstances, we are unable to say that the Tribunal committed an error in condoning the delay. 24. On the question of perversity of the decision of the Tribunal we may also refer to the judgment of the Supreme Court in Sree Meenakshi Mills Ltd. v. CIT [1957] 31 ITR 28. In that judgment, it was noted that only a question of law can be referred for decision of the Court and the decision of the Tribunal on a question of fact can be challenged only if it is not supported by any evidence, or is unreasonable or perverse. The following pithy observations of T.L. Venkatarama Aiyar, J. speaking for the Court are relevant…

Nilons Enterprises Pvt.Ltd, Pune vs. Ward 2(4), Pune

In the result, appeal of the Assessee is allowed

ITA 1600/PUN/2024[2016-17]Status: DisposedITAT Pune15 Jan 2025AY 2016-17

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: Shri Nikhil PathakFor Respondent: Shri Arvind Desai, Addl. CIT-DR
Section 143(3)Section 269TSection 271E

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “A” BENCH : PUNE BEFORE SHRI RAMA KANTA PANDA, VICE PRESIDENT AND MS. ASTHA CHANDRA, JUDICIAL MEMBER I.T.A.No.1600/PUN./2024 Assessment Year 2016-2017 Nilons Enterprises Pvt. The Income Tax Officer, Ltd., 6th Floor, Baner Biz Ward-2(4), Room No.408, Bay, Opp. Syngenta 4th Floor, PMT Bldg., Shankar vs. Baner Road, Baner, PUNE Seth Road, Swargate, PIN – 411 045. PAN AABCN8601N PUNE – 411 037. Maharashtra. Maharashtra. (Appellant) (Respondent) For Assessee : Shri Nikhil Pathak For Revenue : Shri Arvind Desai, Addl. CIT-DR Date of Hearing : 09.12.2024 Date of Pronounceme…

The Commissioner of Income Tax III vs. M/S. Savijana Sea Foods Pvt. Ltd

ITTA/55/2010HC Telangana20 Dec 2024

Bench: J SREENIVAS RAO,ALOK ARADHE

ITO, Ward-2(4), New Delhi vs. Antheia Constructions P.Ltd, New Delhi

In the result, both the appeals filed by the Revenue are dismissed

ITA 4963/DEL/2017[2014-15]Status: DisposedITAT Delhi13 Sept 2024AY 2014-15

Bench: Shri Saktijit Dey, Hon’Ble & Shri S.Rifaur Rahman

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri Kanv Bali, Sr. DR
Section 133Section 142(1)Section 143(2)

…sometime due to unfortunate situation there may be loss or there may not be any transaction. Hence, no disallowance of interest can be made. The appellant also relied upon the judgment of Hon'ble Supreme Court in the case of Sree Meenakshi Mills Ltd. Vs. CIT 63 ITR 207 wherein the Court has held that expenditure incurred not with a view to direct or immediate benefit for the purpose of commercial expediency and in order indirectly to facilitate the carrying on the business is therefore, expenditure laid out wholly and exclusively for the purposes of the trade. ………………….. In view of the above decisions, it is held…

ITO, New Delhi vs. M/S Antheia Constructions Pvt. Ltd., New Delhi

In the result, both the appeals filed by the Revenue are dismissed

ITA 2373/DEL/2017[2013-14]Status: DisposedITAT Delhi13 Sept 2024AY 2013-14

Bench: Shri Saktijit Dey, Hon’Ble & Shri S.Rifaur Rahman

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri Kanv Bali, Sr. DR
Section 133Section 142(1)Section 143(2)

…sometime due to unfortunate situation there may be loss or there may not be any transaction. Hence, no disallowance of interest can be made. The appellant also relied upon the judgment of Hon'ble Supreme Court in the case of Sree Meenakshi Mills Ltd. Vs. CIT 63 ITR 207 wherein the Court has held that expenditure incurred not with a view to direct or immediate benefit for the purpose of commercial expediency and in order indirectly to facilitate the carrying on the business is therefore, expenditure laid out wholly and exclusively for the purposes of the trade. ………………….. In view of the above decisions, it is held…

Aatma Prakash Mental Health Foundation, Indore vs. Commissioner of Income Tax (Exemption), Bhopal

Appeal is allowed for statistical purpose

ITA 107/IND/2024[N.A.]Status: DisposedITAT Indore20 May 2024

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniaatma Prakash Mental Cit (Exemption), Health Foundation, Bhopal बनाम/ 738, Nehru Nagar, Vs. Indore. (Appellant/Assessee) (Respondent/Revenue) Pan: Aaoca9170A Assessee By Shri Apurva Mehta & Shri Rajesh Mehta, Ars Revenue By Shri Ram Kumar Yadav, Cit Dr Date Of Hearing 16.05.2024 Date Of Pronouncement 20.05.2024

Section 12ASection 253(5)Section 8Section 80G(5)

…rcumstances, we are unable to say that the Tribunal committed an error in condoning the delay. 24. On the question of perversity of the decision of the Tribunal we may also refer to the judgment of the Supreme Court in Sree Meenakshi Mills Ltd. v. CIT [1957] 31 ITR 28. In that judgment, it was noted that Page 17 of 24 Aatma Prakash Mental Health Foundation, Indore. only a question of law can be referred for decision of the Court and the decision of the Tribunal on a question of fact can be challenged only if it is not supported by any evidence, or is unreasonable or perverse. The following pithy observations o…

Rabdi Vibhag Progressive Kelavni Mandal, Valsad vs. CIT(Exemption), Ahmedabad

In the result, the appeal filed by the Assessee is allowed for statistical purpose

ITA 797/AHD/2023[NA]Status: DisposedITAT Ahmedabad24 Jan 2024

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)Section 80G(5)(iv)

…ircumstances, we are unable to say that the Tribunal committed an error in condoning the delay. 24. On the question of perversity of the decision of the Tribunal we may also refer to the judgment of the Supreme Court in Sree Meenakshi Mills Ltd. v. CIT [1957] 31 ITR 28. In that judgment, it was noted that only a question of law can be referred for decision of the Court and the decision of the Tribunal on a question of fact can be challenged only if it is not supported by any evidence, or is unreasonable or perverse. The following pithy observations of T.L. Venkatarama Aiyar, J. speaking for the Court are relevant…

The Dy. Commissioner of Income Tax, Central Circle-6(4), Mumbai vs. M/S Tapir Construction Limited, Mumbai

In the result, appeal filed by the assessee is allowed in terms indicated hereinabove

ITA 2145/MUM/2023[2018-2019]Status: DisposedITAT Mumbai13 Dec 2023AY 2018-2019

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Bledcit – Central Circle – 6(4) V. M/S. Tapir Constructions Limited Room No. 1925, 19Th Floor M-62 & 63, 1St Floor Air India Building Connaught Place Nariman Point, Mumbai - 400021 New Delhi – 110001, New Delhi Pan: Aaect9858L (Appellant) (Respondent)

Section 142(1)Section 143(1)Section 143(2)

…n Page No. 3 to 8 of the assessment order. 5. After considering the submissions of the assessee, Assessing Officer rejected the claim of the assessee by relying on the decision of Hon’ble Supreme Court in the case of Shree Maeenakshi Mills Ltd. v. CIT [1967] 63 ITR 207 (SC). The Assessing Officer came to the conclusion that the Hon’ble Supreme Court in unambiguous terms has held that it is only the business expenditure incurred for carrying on the business of the assessee which is allowable. In the present case, the income declared by the assessee does not pertain to its stated business as that of undertaking re…

Addl. CIT, Special Range- 1, New Delhi vs. Amway India Enterprises Pvt. Ltd., New Delhi

In the result, the appeal of the revenue is dismissed

ITA 6707/DEL/2018[2012-13]Status: DisposedITAT Delhi08 May 2023AY 2012-13

Bench: Shri C.M. Garg & Dr. B. R. R. Kumaraddl. Cit, Vs. Amway India Enterprises Pvt. Ltd, 1St Floor, Plot No. 8, Elegance Special Range-1, New Delhi Tower, Jasola, New Delhi -110025 (Appellant) (Respondent) Pan: Aaaca5603Q Assessee By : Sh. Sudesh Garg, Adv Sh. Prince Bansal, Ca Ms. Bhavya Garg, Ca Revenue By: Sh. P. Praveen Sidharth, Cit Dr Date Of Hearing 16/02/2023 Date Of Pronouncement 08/05/2023

For Appellant: Sh. Sudesh Garg, AdvFor Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 32Section 37(1)

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “A”: NEW DELHI BEFORE Shri C.M. Garg, Judicial Member AND Dr. B. R. R. Kumar, Accountant Member Addl. CIT, Vs. Amway India Enterprises Pvt. Ltd, 1st Floor, Plot NO. 8, Elegance Special Range-1, New Delhi Tower, Jasola, New Delhi -110025 (Appellant) (Respondent) PAN: AAACA5603Q Assessee by : Sh. Sudesh Garg, Adv Sh. Prince Bansal, CA Ms. Bhavya Garg, CA Revenue by: Sh. P. Praveen Sidharth, CIT DR Date of Hearing 16/02/2023 Date of pronouncement 08/05/2023 O R D E R PER C. M. GARG, J. M.: 1. This is an appeal filed by the revenue against the order of the ld CIT(A)-11, New…

Shaju Ninan John, Ernakulam vs. The DCIT, Circle- International Taxation, Kochi

In the result, the appeal by the assessee is dismissed

ITA 688/COCH/2022[2017-2018]Status: DisposedITAT Cochin02 Mar 2023AY 2017-2018

Bench: Shri Sanjay Arora (Accountant Member), Shri Sandeep Gosain (Judicial Member)

For Appellant: Shri Suresh Kumar Varma K, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(3)

…ter is well-settled, and toward which we may cite some, as under: Omar Salay Mohamed Sait v. CIT [1959] 37 ITR 151 (SC) CIT v. Daulat Ram Rawatmull [1973] 87 ITR 349 (SC) CIT v. Radha Kishan Nandlal [1975] 99 ITR 143 (SC) In Meenakshi Mills Ltd. v. CIT [1957] 31 ITR 28 (SC), it stands clarified that in appreciating facts, they must be considered not in isolation, but by assessing the cumulative effect of all the facts in their setting as a whole. In CIT v. Walchand & Co. (P.) Ltd. [1967] 65 ITR 381 (SC), it was held that the Tribunal is to deal with and determine questions which arise out of the subject-matter of…

ITO Ward - 2(2), New Delhi vs. All Check Deals India Pvt. Ltd., New Delhi

The appeal of the revenue is dismissed

ITA 2923/DEL/2019[2014-15]Status: DisposedITAT Delhi24 Nov 2022AY 2014-15

Bench: Shri Shamim Yahya & Shri Anubhav Sharmaito, Vs. All Check Deals India Pvt. Ltd, Ward-2(2). 94, Meghdoot Building, Gf- New Delhi 12A, Nehru Place, New Delhi (Appellant) (Respondent)

For Appellant: Shri Sharat Rao, AdvFor Respondent: Shri Kanav Bali, Sr. DR
Section 143(3)Section 37(1)Section 40Section 40A(2)(a)Section 94C

…ess of the appellant and same are allowable. Hence, the disallowance made by the AO is deleted. The appellant has relied upon the judgments of Hon’ble Supreme Court in the case of CIT Vs. Malyalam Plantation Ltd. 53 ITR 140, Shri Meenakshi Mills Ltd. Vs. CIT, 63 ITR 207, CIT Vs. Dhanrajgirji Raja Narsingirji, 94 ITR 544 (SC), Birla Cotton Spinning and Weaving Mills Ltd. Vs. CIT, 64 ITR 568 (Calcutta), CIT Vs. Modi Revlon Pvt. Ltd., 26 taxmann.com 133 (Delhi) in support of its contention that expenses incurred for the purposes of business has to be allowed. These judgments supports the argument of the appellant wh…

Manglam Arts, Jaipur vs. DCIT, Circle-4, Jaipur

In the result, appeal of the assessee is allowed

ITA 207/JPR/2022[2018-2019]Status: DisposedITAT Jaipur10 Aug 2022AY 2018-2019
For Appellant: Shri P. C. Parwal (CA)For Respondent: Shri A.S. Nehra (Addl. CIT)
Section 142(1)Section 143(1)Section 143(2)Section 244ASection 250

…xpenditure. In support of his contention, the ld. A/R placed reliance on the following case laws :- (1) Bikaner Gypsums Ltd. Vs. CIT(1991) 187 ITR 39 (SC) (2) Dalmia Jain & Co. Ltd. Vs. CIT (1971) 81 ITR 754 (SC) (3) Sree Meenakshi Mills Ltd. Vs. CIT (1967) 63 ITR 207 (SC) (4) CIT Vs. O.P.N. Arunachala Nadar (1983) 141 ITR 620 (Madras) (HC) While concluding, the ld. A/R submitted that from the above decisions it is evident that when the litigation expenditure is incurred to protect the business, the same is revenue expenditure. In the present case, the assessee is not the owner of asset but it is possessing t…

Kalaignar Tv Pvt. Ltd., Chennai vs. ACIT Non Corporate Circle 20(1), Chennai

ITA 2442/CHNY/2018[2012-13]Status: DisposedITAT Chennai20 Jul 2022AY 2012-13

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 2442, 2443 & 2444/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13, 2013-14 & 2014-15 Kalaignar Tv Pvt. Ltd., The Assistant Commissioner Of “Anna Arivalayam”, 367/369, Anna Vs. Income Tax, Salai, Teynampet, Chennai 600 018. Non Corporate Circle 20(1), [Pan:Aadck0898E] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Sandeep Bagmar, Advocate ""थ" की ओर से/Respondent By : Shri M. Swaminathan, Sr. Standing Counsel & Ms. Pushpa, Jr. Standing Counsel सुनवाई की तारीख/ Date Of Hearing : 11.05.2022 घोषणा की तारीख /Date Of Pronouncement : 20.07.2022 आदेश /O R D E R Per V. Durga Rao: These Three Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai, All Dated 30.05.2018 Relevant To The Assessment Years 2012- 13, 2013-14 & 2014-15. Since The Facts Are Identical & Common Issue Has Been Raised, All The Appeals Were Heard Together & Being Disposed Off By This Common Order For The Sake Of Brevity. In The Assessment Year 2012-13, The Assessee Has Raised Following Grounds: “The Grounds Of Appeal Stated Hereunder Are Independent Of & Without Prejudice To One Another:

For Appellant: Shri Sandeep Bagmar, AdvocateFor Respondent: Shri M. Swaminathan, Sr. Standing Counsel
Section 37Section 37(1)

…TR 18 (P&H) 13. Gujarat Agro Oil Enterprises Ltd. v. CIT [2002] 256 ITR 230 (Guj) 14. Hiranandani Akruti JV v. DCIT [2017] 88 taxmann.com 209 (Mumbai-Trib) 15. CIT v. Chandulal Keshavlal & Co. [19601 38 ITR 601 (SC) 16. Sree Meenakshi Mills Ltd. v. CIT [19671 63 ITR 207 (SC) 17. The Weavers Mills Ltd. v. Balkis Ammal & Ors AIR 1969 MAD 462 18. McKnight (Inspector of Taxes) v. Sheppard [1999] 1 WLR 1333 5. On the other hand, the ld. DR has submitted that as per section 37(1) of the Act, such eligible expenditure should not be in the nature of capital expenditure, personal expenditure and must have been laid out or…

Kalaignar Tv Pvt. Ltd., Chennai vs. ACIT Non Corporate Circle 20(1), Chennai

ITA 2444/CHNY/2018[2014-15]Status: DisposedITAT Chennai20 Jul 2022AY 2014-15

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 2442, 2443 & 2444/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13, 2013-14 & 2014-15 Kalaignar Tv Pvt. Ltd., The Assistant Commissioner Of “Anna Arivalayam”, 367/369, Anna Vs. Income Tax, Salai, Teynampet, Chennai 600 018. Non Corporate Circle 20(1), [Pan:Aadck0898E] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Sandeep Bagmar, Advocate ""थ" की ओर से/Respondent By : Shri M. Swaminathan, Sr. Standing Counsel & Ms. Pushpa, Jr. Standing Counsel सुनवाई की तारीख/ Date Of Hearing : 11.05.2022 घोषणा की तारीख /Date Of Pronouncement : 20.07.2022 आदेश /O R D E R Per V. Durga Rao: These Three Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai, All Dated 30.05.2018 Relevant To The Assessment Years 2012- 13, 2013-14 & 2014-15. Since The Facts Are Identical & Common Issue Has Been Raised, All The Appeals Were Heard Together & Being Disposed Off By This Common Order For The Sake Of Brevity. In The Assessment Year 2012-13, The Assessee Has Raised Following Grounds: “The Grounds Of Appeal Stated Hereunder Are Independent Of & Without Prejudice To One Another:

For Appellant: Shri Sandeep Bagmar, AdvocateFor Respondent: Shri M. Swaminathan, Sr. Standing Counsel
Section 37Section 37(1)

…TR 18 (P&H) 13. Gujarat Agro Oil Enterprises Ltd. v. CIT [2002] 256 ITR 230 (Guj) 14. Hiranandani Akruti JV v. DCIT [2017] 88 taxmann.com 209 (Mumbai-Trib) 15. CIT v. Chandulal Keshavlal & Co. [19601 38 ITR 601 (SC) 16. Sree Meenakshi Mills Ltd. v. CIT [19671 63 ITR 207 (SC) 17. The Weavers Mills Ltd. v. Balkis Ammal & Ors AIR 1969 MAD 462 18. McKnight (Inspector of Taxes) v. Sheppard [1999] 1 WLR 1333 5. On the other hand, the ld. DR has submitted that as per section 37(1) of the Act, such eligible expenditure should not be in the nature of capital expenditure, personal expenditure and must have been laid out or…