Taparia Tools Ltd. v. JCIT

372 ITR 605Supreme Court of India2015#223 most cited

What is Taparia Tools Ltd. v. JCIT authority for?

An expenditure does not automatically become capital in nature merely because it results in some enduring benefit for the assessee; it can be treated as revenue expenditure if incurred for genuine business purposes.

343

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2013 to 2026.

Also referred to as

Taparia Tools Ltd. v. JCIT · 372 ITR 605 · SC · 2015 · section 37(1) · revenue expenditure · capital expenditure · enduring benefit test · deferred revenue expenditure · expenditure disallowance · business expenditure · allowability of expenditure

Also reported as

55 Taxmann.com 361276 CTR 1231 Taxmann 5

Sections most often in play

Section 143(3)Section 37(1)Section 40(a)(ia)Section 263Section 271(1)(c)Section 148Section 14ASection 115JB
Read the full judgment

Issues it is cited on

section 50(1)section 80absection 54esection 80msection 10(33)section 10(15)section 14a(1)section 54eclong-term capital assetsection 36(1)(viii)mat creditdisallowance of interest expenditure

Judgments citing Taparia Tools Ltd. v. JCIT

Navratan Management Private Limited, Mumbai vs. Dy.Comm Central Circle 8(4) Mumbai, Mumbai

ITA 3586/MUM/2024[2017-18]Status: DisposedITAT Mumbai04 Apr 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry

Section 132Section 143(1)Section 153ASection 2(14)Section 250Section 56(2)(via)Section 56(2)(vii)Section 56(2)(viia)

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “SMC", MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER ITA No.3586/M/2024 Assessment Year: 2017-18 M/s. Navratan Management Private Limited, A 205, Godrej Colleseum off Western Express Highway Near Pan Bazar, Sion, Maharashtra - 400 022 PAN: AACCN5861B (Appellant) Vs. Dy. Commissioner, Central Circle 8(4), Room No.658, 6th Floor, Aaykar Bhavan, M.K. Road, Mumbai Maharashtra - 400022 (Respondent) Present for: Assessee by Revenue by Date of Hearing Date of Pronouncement : Shri Dhaval Shah, Ld. A.R. a/w Ms. Tisha Bagh, Ld. A.R. : Shri Kiran Unavekar, Ld…

Dy. Commissioner of Income Tax, Central Circle-5(1), Mumbai vs. Itd Itd Cem Joint Venture, Mumbai

In the result, appeals of both, assessee and revenue are decided as per the table below:

ITA 5232/MUM/2024[2015-16]Status: DisposedITAT Mumbai17 Mar 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Shri Amol Kirtane, CIT DR
Section 1Section 143(3)Section 148Section 148A

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos. 4539, 4568 and 4532/MUM/2024 Assessment Years: 2015-16, 2016-17 and 2019-20 ITD Cementation India Ltd., Deputy Commissioner of 9th Floor, Prima Bay, Income-tax, Tower-B, Saki Vihar Road, Central Circle 5(1), Powai, Vs. Mumbai Mumbai – 400 072 (PAN : AAACT1426A) (Appellant) (Respondent) ITA Nos. 5235 and 5234 /MUM/2024 Assessment Years: 2015-16 and 2016-17 Deputy Commissioner of ITD Cementation India Ltd., Income-tax, 9th Floor, Prima Bay, Central Circle 5(1), To…

Itd Cementation India Limited, Mumbai vs. The Deputy Commissioner of Income Tax, Central Circle 5(1), Mumbai

In the result, appeals of both, assessee and revenue are decided as per the table below:

ITA 4539/MUM/2024[2015-16]Status: DisposedITAT Mumbai17 Mar 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Shri Amol Kirtane, CIT DR
Section 1Section 143(3)Section 148Section 148A

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos. 4539, 4568 and 4532/MUM/2024 Assessment Years: 2015-16, 2016-17 and 2019-20 ITD Cementation India Ltd., Deputy Commissioner of 9th Floor, Prima Bay, Income-tax, Tower-B, Saki Vihar Road, Central Circle 5(1), Powai, Vs. Mumbai Mumbai – 400 072 (PAN : AAACT1426A) (Appellant) (Respondent) ITA Nos. 5235 and 5234 /MUM/2024 Assessment Years: 2015-16 and 2016-17 Deputy Commissioner of ITD Cementation India Ltd., Income-tax, 9th Floor, Prima Bay, Central Circle 5(1), To…

Itd Cementation India Limited, Mumbai vs. The Deputy Commissioner of Income Tax, Central Circle 5(1), Mumbai

In the result, appeals of both, assessee and revenue are decided as per the table below:

ITA 4532/MUM/2024[2019-20]Status: DisposedITAT Mumbai17 Mar 2025AY 2019-20

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Shri Amol Kirtane, CIT DR
Section 1Section 143(3)Section 148Section 148A

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos. 4539, 4568 and 4532/MUM/2024 Assessment Years: 2015-16, 2016-17 and 2019-20 ITD Cementation India Ltd., Deputy Commissioner of 9th Floor, Prima Bay, Income-tax, Tower-B, Saki Vihar Road, Central Circle 5(1), Powai, Vs. Mumbai Mumbai – 400 072 (PAN : AAACT1426A) (Appellant) (Respondent) ITA Nos. 5235 and 5234 /MUM/2024 Assessment Years: 2015-16 and 2016-17 Deputy Commissioner of ITD Cementation India Ltd., Income-tax, 9th Floor, Prima Bay, Central Circle 5(1), To…

Scott Edil Advance Research Laboratories and Education Limited, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 857/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh03 Mar 2025AY 2016-17
Section 127Section 132Section 153ASection 153DSection 2(22)(e)

…compliance of requirement of s. 36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Scott Edil Advance Research Laboratories and Education Limited, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 856/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh03 Mar 2025AY 2015-16
Section 127Section 132Section 153ASection 153D

…t compliance of requirement of s.36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Scott Edil Advance Research Laboratories and Education Limited, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 845/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh03 Mar 2025AY 2017-18
Section 127Section 132Section 153ASection 153DSection 2(22)(e)

…t compliance of requirement of s.36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Scott Edil Advance Research Laboratories and Education Limited, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 843/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh03 Mar 2025AY 2012-13
Section 127Section 132Section 153ASection 153D

…t compliance of requirement of s.36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Scott Edil Pharmacia Ltd., Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 833/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh03 Mar 2025AY 2017-18
Section 127Section 132Section 153ASection 153D

…t compliance of requirement of s.36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Scott Edil Pharmacia Ltd., Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 832/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh03 Mar 2025AY 2016-17
Section 127Section 153DSection 2(22)(e)

…compliance of requirement of s. 36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Scott Edil Pharmacia Ltd., Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 829/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh03 Mar 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./Ita No. 579/Chd /2023 निर्धारण वर्ष / Assessment Year : 2017-18 & आयकर अपील सं./Ita Nos.582 To 584/Chd/ 2023 निर्धारण वर्ष / Assessment Years : 2014-15 To 2016-17 & आयकर अपील सं./Ita No. 591/Chd /2023 निर्धारण वर्ष / Assessment Year : 2018-19

Section 127Section 132Section 153ASection 153D

…t compliance of requirement of s.36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Shri Balram Krishan, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 732/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh03 Mar 2025AY 2018-19
Section 127Section 132Section 153ASection 153D

…t compliance of requirement of s.36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Shri Balram Krishan, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 731/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh03 Mar 2025AY 2017-18
Section 127Section 132Section 153ASection 153DSection 2(22)

…compliance of requirement of s. 36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Shri Balram Krishan, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 730/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh03 Mar 2025AY 2016-17
Section 127Section 132Section 153ASection 153DSection 2

…t compliance of requirement of s.36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Shri Balram Krishan, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 728/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh03 Mar 2025AY 2014-15

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./Ita No. 579/Chd/2023 निर्धारण वर्ष / Assessment Year : 2017-18 & आयकर अपील सं./Ita Nos.582 To 584/Chd/2023 निर्धारण वर्ष / Assessment Years : 2014-15 To 2016-17 & आयकर अपील सं./Ita No. 591/Chd/2023 निर्धारण वर्ष / Assessment Year : 2018-19 Maxport India Pvt. Ltd. C/O Parikshit Aggarwal, Chartered Accountant, H. No. 3035, Sector 27D, Chandigarh- 160019. स्था.लेखा सं./Pan No: Aaicm9120E अपीलाथ/Appellant बनाम प्रथीय/Respondent Deputy Commissioner Of Income-Tax, Centre Circle-1, Chandigarh. & आयकर अपील सं./Ita Nos.482 & 483/Chd/2023 निर्धारण वर्ष / Assessment Years : 2017-18 & 2018-19 Vaishali Aggarwal C/O Parikshit Aggarwal, Chartered Accountant, H No. 3035, Sector 27D, Chandigarh- 160022. स्था.लेखा सं./Pan No: Aaqpa4025M अपीलाथ/Appellant बनाम प्रथीय/Respondent Deputy Commissioner Of Income-Tax, Centre Circle-1, Chandigarh. & आयकर अपील सं./Ita No. 846/Chd/2023

Section 127Section 132Section 153ASection 153DSection 2(22)(e)

…t compliance of requirement of s.36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Shri Balram Krishan, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 726/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh03 Mar 2025AY 2012-13
Section 153A

…t compliance of requirement of s.36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Maxport India Private Limited, Chandigarh vs. Dy. Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 583/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh03 Mar 2025AY 2015-16
Section 127Section 132Section 153ASection 153DSection 2(22)(e)

…t compliance of requirement of s.36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Maxport India Private Limited, Chandigarh vs. Dy. Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 582/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh03 Mar 2025AY 2014-15
Section 127Section 132Section 153ASection 153D

…t compliance of requirement of s.36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

Sanjeev Aggarwal, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 489/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh03 Mar 2025AY 2017-18
Section 127Section 132Section 153ASection 153D

…t compliance of requirement of s.36(2). He has contended that it was a settled principle of law that reflection in accounts of a transaction was not determinative of its allowability for tax purposes and vice-versa as held in Taparia Tools Ltd. vs. CIT [2015] 372 ITR 605 (SC). He has further relied upon the decision of Bombay High Court in the case of “PCIT vs. JSW Steel Ltd” [2020] 115 taxmann.com 165 (Bombay) to contend that that a new claim for the first time can be made in the ITR filed u/s 153A post search though, such claim was not made in the ITR filed u/s 139. He has further submitted that the taxability…

ACIT-2(3)(1), Mumbai vs. Hdfc Bank Ltd ( Merged Entity Hdfc Investments Limited ), Mumbai

ITA 2980/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Jan 2025AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate a

…IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos.4315 and 4316/MUM/2007 Assessment Years: 2002-03 and 2003-04 ITA Nos.3861 and 3862/Mum/2009 Assessment Years: 2004-05 and 2005-06 ITA Nos.5033/Mum/2010, 5442/Mum/2011, 2868/Mum/2012 Assessment Years: 2006-07 to 2008-09 ITA Nos.2093, 5885, 2609, 2610 and 4983/Mum/2017 Assessment Years: 2009-10 to 2013-14 ITA Nos.2665 and 2666/Mum/2024 Assessment Years: 2014-15 and 2015-16 ITA Nos.1890, 1891, 1892, 1893 and 3717/Mum/2023 and Assessment Years: 2…