“commercial expediency”

Business ExpensesSection 37Section 371,685 judgments

REGUS SOUTH MUMBAI BUSINESS CENTRE PVT. LTD.,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - 14(1)(2), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 6104/MUM/2025[2012-13]Status: DisposedITAT Mumbai26 Mar 2026AY 2012-13

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokarregus South Mumbai Dcit - 14(1)(2), Business Centre Mumbai Private Limited, Vs. Aayakar Bhavan, M. Level 4, Dynasty K. Road, New Marine Business Park, Andheri Lines. Mumbai- Kurla Road, J. B. Nagar 400 020 S.O, Mumbai – 400 059 Pan/Gir No. Aadcr6068H (Applicant) (Respondent) Assessee By Shri Ketan Ved, Ld. Ar Revenue By Smt. Usha Gaikwad, Ld. Dr Date Of Hearing 16.03.2026 Date Of Pronouncement 26.03.2026

Section 143(3)

cannot, by itself, be a reason to disallow the claim. In modern business structures, centralized support functions are a matter of business organization and commercial expediency. The tax authorities cannot insist that every legal entity must duplicate the same finance, HR, marketing and IT infrastructure separately in order to claim ... armchair of the businessman and dictate how business support services should be internally organised. So long as the expenditure is incurred on grounds of commercial expediency and has nexus with the business of the assessee, deduction under section 37(1) cannot be denied merely because the expenditure was first incurred

FAIRCHEM ORGANICS LTD.,,AHMEDABAD vs. ACIT, CIR-15(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 6143/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Mar 2026AY 2020-21

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarfairchem Organics Acit Circle - Limited 15(1)(1), 253/P & 312, Village Vs. Aayakar Bhawan, M. Chekhala, Sanand K. Road, Churchgate, Kadi Highway, Taluka Mumbai-400 020 Sanand, Distt Ahmedabad, Gujarat – 382 115. Pan/Gir No. Aadcf6900E (Applicant) (Respondent) Assessee By Shri Saurabh Soparkar, Ld. Ar Revenue By Shri Ankit Tiwari, Ld. Dr Date Of Hearing 04.03.2026 Date Of Pronouncement 20.03.2026

Section 115JSection 143(3)Section 250Section 36(1)(iii)

have substantial borrowings and, therefore, the explanation of the assessee was not satisfactory. The Assessing Officer further held that the assessee failed to demonstrate commercial expediency in granting such advances and also failed to establish nexus between own funds and advances. Relying upon the provisions of section ... recorded that the assessee merely furnished breakup of advances but failed to provide supporting documents such as invoices, agreements, or other evidences to establish commercial expediency. The CIT(A) further held that the assessee failed to establish nexus between availability of own funds and advances and, therefore, the contention regarding

TECHPARK HOTELS PVT LTD,GURGAON vs. ADDI. CIT SPECIAL RANGE-9, NEW DELHI

In the result, the appeal filed by the Assessee is allowed

ITA 9450/DEL/2019[2015-16]Status: DisposedITAT Delhi20 Mar 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumartechpark Hotels Pvt. Ltd., Addl. Cit, Ground Floor, Central Wing, Special Range-9, Thapar House 124, Janpath, Vs. New Delhi. New Delhi-110001. Pan-Aabce5833H (Appellant) (Respondent) Assessee By Shri Neeraj Jain, Adv. & Shri Tavish Verma, Adv. Ms. Harpreet Kaur Hansra Sr. Dr Department By Date Of Hearing 20.01.2026 Date Of Pronouncement 20.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Assessee Is Against Order Dated 11.09.2019 Of The Learned Commissioner Of Income Tax (Appeals), New Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 30.12.2017 Of The Ld. Assessing Officer U/S 143(3) Of The Act For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Filed Return Declaring Loss Of Rs.23,06,28,106/- On 30.11.2015. Notice U/S 143(2) Dated 22.09.2016 Was Issued. Notices U/S 142(1) Were Issued. Sh. Nikhil Agarwal & Shri Nirmal Malpani, Ca Appeared & Filed Details. On Completion Of Proceedings, Ld. Ao Vide Order Dated Techpark Hotels Pvt. Ltd. Vs. Acit

Section 142(1)Section 143(2)Section 143(3)Section 154Section 234DSection 250Section 56(2)Section 56(2)(viib)

that Income Tax Department cannot sit in the armchair of businessman to decide what is profitable and how the business should be carried out. Commercial expediency has to be seen from the point of view of businessman. Here in this case if the investment has made keeping assessee

ESCORTS LTD.,FARIDABAD vs. ADDL.CIT, SPECIAL RANGE-3, NEW DELHI

Appeal is allowed

ITA 7394/DEL/2019[2016-17]Status: DisposedITAT Delhi13 Mar 2026AY 2016-17

Section 143(3)

copy of RBI letter\nenclosed - page payments have since been made in subsequent\nyears thereby ending this matter finally.\nThe appellant also explained the commercial expediency of the\nexpenditure incurred vide the same letter dated 7th December 2018.\nThe relevant extracts are reproduced below:\n\"Commercial Expediency The expenditure ... essential to recapture the\nUS market.\niii) Corporate guarantee was given for the debts of subsidiary\ncompany towards their suppliers due to commercial expediency.\nThe whole idea to provide corporate guarantee was to promote the\nbusiness interest of the assessee company and gain a foothold in a\nhighly competitive

THE CAMP MULTIPURPOSE PRIMARY AGRICULTURE COOPERATIVE SOCIETY LIMITED,PERNEM, GOA vs. INCOME TAX OFFICER, WARD 2 (1), PANAJI, GOA

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

ITA 55/PAN/2026[2016-17]Status: DisposedITAT Panaji11 Mar 2026AY 2016-17

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Section 80P(2)(a)Section 80P(2)(d)

amounts are invested in Co-operative Credit societies, Co-operative Banks and Scheduled Banks. Investments in scheduled banks are made on account of commercial expediency of quick liquidity whenever the need arises. Whereas the provisions of section 80P(2) (a) (i) of the Act are dealt in cases were

UFX VENTURES PVT. LTD.,CHENNAI vs. ACIT, CORPORATE CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessee are

ITA 2273/CHNY/2025[2014-15]Status: DisposedITAT Chennai11 Mar 2026AY 2014-15

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Ms. Shilpa Susan Kuriachan, CAFor Respondent: Ms. T. Mythili, JCIT

Section 143(3)Section 250Section 37

entire interest expenditure resulting in double disallowance to that extent. It was further contended that the advances given to sister concerns were out of commercial expediency as the business of the assessee was largely dependent on the support services rendered by those concerns. The advances were periodically adjusted against ... support of the contention that interest cannot be disallowed where advances are made to sister concerns on account :- 6 -: ITA Nos.2272 & 2273/CHNY/2025 of commercial expediency, the Ld. AR relied on the judgment of the Hon’ble Supreme Court in the case of S.A. Builders

UFX VENTURES PVT. LTD.,CHENNAI vs. ACIT, CORPORATE CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessee are

ITA 2272/CHNY/2025[2013-14]Status: DisposedITAT Chennai11 Mar 2026AY 2013-14

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Ms. Shilpa Susan Kuriachan, CAFor Respondent: Ms. T. Mythili, JCIT

Section 143(3)Section 250Section 37

SHRI BRAHMANATH CREDIT SOUHARD SAHAKARI SANGH NIYAMIT,NIPPANI vs. ITO 1 NIPPANI, NIPPANI

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

ITA 66/PAN/2026[2013-14]Status: DisposedITAT Panaji10 Mar 2026AY 2013-14

Bench: Shri Pavan Kumar Gadalei T A. Nos.66/Pan/2026 (A.Y. 2013-14 ) Shri Brahmanath Credit Vs I.T.O-Ward-1, Souhard Sahakari Sangh Nemchand Building, . Niyamat, 747,Ashoknagar, 185/C, Chikodi Road, Nippani-591237, Nippani, Karnataka. Belagavi-591237, Karnataka. Pan .No. Aaaas1063Q (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.U.G.Ammangi.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.03.2026 घोषणा की तारीख/Date Of Pronouncement 10.03.2026 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Nfac/Cit(A) U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Deduction Of Interest Income From Cooperative Society, Cooperative Banks & Nationalized Banks U/Sec80P(2)(D) Of The Act. 2. The Brief Facts Of The Case Are That, The Assessee Is A Cooperative Credit Society & Is Engaged In Activities Of Providing Credit Facilities To Its Members. The Assessee Has Filed The Return Of Income For The A.Y 2013-14 On 2 Ita. No..66/Pan/2026 Shri Brahmanath Credit Souhard Sahakari Sangh Niyamit. 30.09.2013 Disclosing A Total Income Of Rs.Nil After Claiming Deduction Of Rs.78,06,780/- U/Sec 80P(2)(A)(I) Of The Act. Subsequently The Case Was Selected For Scrutiny Under Cass & Order U/Sec143(3) Of The Act Was Passed Disallowing The Claim U/Sec80P(2)(A)(I) Of The Act Of Rs.78,06,780/- & Disallowance U/Sec40(A)(Ia) Of The Act Of Rs.76,274/- & Assessed The Total Income Of Rs.78,83,054/- Vide Order Dated21.07.2021.Aggrived By The Order, On Appeal To The Cit(A), The Appeal Was Partly Allowed & The Assessee Has Preferred Second Appeal Before The Honble Tribunal & Vide By Order

Section 80PSection 80P(2)(a)Section 80P(2)(d)

ILOVE DIAMONDS PVT. LTD.,CHENNAI vs. ACIT, CC-2,, CHENNAI

The appeal of the assessee is partly allowed

ITA 2005/CHNY/2025[2016-17]Status: DisposedITAT Chennai09 Mar 2026AY 2016-17

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2005/Chny/2025 िनधा$रण वष$ /Assessment Year: 2016-17

For Appellant: Mr. D. Anand, AdvocateFor Respondent: Mr. R. Anitha, Addl. CIT

Section 131Section 250Section 271(1)(c)Section 37Section 68

properly appreciating that the amount was genuinely irrecoverable and written off in the books of accounts. The learned CIT(A) failed to consider the commercial expediency of the loan and its connection to the Appellant's business, despite the AO's erroneous interpretation of Section 37 and the requirement

DEPUTY COMMISSIONER OF INCOME TAX-2(2)(1), MUMBAI, AAYAKAR BHAVAN, CHURCHGATE vs. MUMBAI INTERNATIONAL AIRPORT LIMITED, MUMBAI

ITA 7035/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

Section 14ASection 250Section 28Section 32(1)(ii)Section 35D

nthe payment has been made by the appellant to AAI and\nnot to its own employees. The payment has-been made out\nof commercial expediency and under contractual\nobligation. The appellant has not floated any voluntary\nretirement scheme of its own, but the payment has been\nmade under an agreement

MUMBAI INTERNATIONAL AIRPORT LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(2)(1), MUMBAI, MUMBAI

The appeal of the assessee is allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

ITA 6692/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2014-15 Mumbai International Vs. Dcit, Circle – 2(2)(1) Airport Ltd., Aayakar Bhavan, Mk Road 1St Floor, Terminal-1B, New Marine Lines, Mumbai – Chhatrpati Shivaji 400020. International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) A.Y:2014-15 Dcit, Circle – 2(2)(1) Vs. Mumbai International Aayakar Bhavan, Mk Road Airport Ltd., New Marine Lines, Mumbai – 1St Floor, Terminal-1B, 400020. Chhatrpati Shivaji International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) Assessee By Shri Saurabha Soparkar Virtually Appeared Revenue By Shri Annavaram Kosuri, Sr. Ar Date Of Hearing 25.02.2026 Date Of Pronouncement 09.03.2026 आदेश / Order Per Makarand V Mahadeokar, Am: These Cross Appeals Are Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals) Under Section 250 Of The Mumbai International Airport Ltd., Mumbai Income-Tax Act, 1961 Dated 05.08.2025 In The Case Of The Assessee For Assessment Year 2014–15. The Assessment In The Present Case Was Originally Completed By The Assessing Officer Under Section 143(3) Of The Act Vide Order Dated 30.12.2017. Since The Issues Involved In The Appeals Of The Revenue As Well As The Assessee Arise Out Of The Same Appellate Order Of The Ld. Cit(A), These Appeals Were Heard Together & Are Being Disposed Of By Way Of This Common Order For The Sake Of Convenience & Brevity.

Section 143(3)Section 14ASection 250Section 28Section 32(1)(ii)Section 35D

payment has been made by the appellant to AAI and not to its own employees. The payment has-been made out of commercial expediency and under contractual obligation. The appellant has not floated any voluntary retirement scheme of its own, but the payment has been Mumbai International Airport Ltd., Mumbai

SHRI MALLIKARJUN URBAN CO OPERATIVE CREDIT SOCIETY LIMITED,BELAGAVI vs. ITO WARD 1 BELGAUM, BELGAUM

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 65/PAN/2026[2017-18]Status: DisposedITAT Panaji06 Mar 2026AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Section 80PSection 80P(2)(a)Section 80P(2)(d)

SHRI K.P. MAGENNAVAR LAXMI CREDIT SOUHARDA SAHAKARI SANGH LTD.MANJARI.,CHIKODI vs. INCOME TAX OFFICER, WARD-1, NIPPANI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 33/PAN/2026[2015-2016]Status: DisposedITAT Panaji27 Feb 2026AY 2015-2016

Bench: Shri Pavan Kumar Gadalei T A. No.33/Pan/2026 (A.Y. 2015-16 ) Shri K.P.Magennavar Laxmi Vs I.T.O-Ward-1, Credit Souharda Sahakari Nemchand Building, . Sangh Limited, 747,Ashoknagar, 521,Laxmibuilding,Mainroad, Nipani-591237, Manjari, Chikodi, Karnataka. Belagavi-591213, Karnataka. Pan .No. Aabas3175N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Jaykumar Patil.Ar Revenue By Smt.Thamba Mahendra.Sr.Dr सुनवाई की तारीख/Date Of Hearing 25.02.2026 घोषणा की तारीख/Date Of Pronouncement 27.02.2026 Order Per Pavan Kumar Gadale, Jm: The Assessee Has Filed The Appeal Against The Order Of Addl/Jcit(A)-7 Mumbai Passed U/Se 143(3) & U/Sec250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Claim Of Deduction U/Sec80P(2)(A)(I) Of The Ac & Without Prejudice Alternate Relief U/Sec80P(2)(D) Of The Act On Interest Income From Cooperative Banks & Scheduled Banks. 2. The Brief Facts Of The Case Are That, The Assessee Souhard Credit Cooperative Society Is Engaged In Providing

Section 80P(2)(a)Section 80P(2)(d)

SHAILESHKUMAR DAHYABHAI PATEL,VADODARA, GUJARAT vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 2(1)(2) (NOW DCIT CIRCLE 2(1)(1), VADODARA, GUJARAT, VADODARA, GUJARAT

In the result, Ground Number 7 of the assessee’s appeal is allowed

ITA 2131/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Milin Mehta & Shri Bhavin Marfatia, ARsFor Respondent: Shri Rameshwar P Meena, Sr. DR

Section 234BSection 234CSection 270ASection 271ASection 272A(1)(b)Section 6Section 68Section 69ASection 69C

assessee was charged only at 9%. The Assessing Officer held that interest paid beyond 12% was excessive and not justified on grounds of commercial expediency, the and therefore disallowed excess interest of ₹35,21,790/-. The Assessing Officer also noticed a mismatch in advances received from Shri Pathik D. Vachhani ... businessman would act, and that the authorities must not look at the matter from their viewpoint, but that of a prudent businessman impelled by commercial expediency. 5.3. Respectfully following the above decisions, I am also of the view that the AO has no power to sit on the chair

BANGALORE UNION SERVICES PVT. LTD.,CHENNAI vs. DCIT, CORPORATE CIRCLE-1(2), CHENNAI

In the result, the appeal of the assessee is allowed

ITA 2483/CHNY/2025[2012-13]Status: DisposedITAT Chennai26 Feb 2026AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. S. Sridhar, Advocate (by Virtual)For Respondent: Ms. Gouthami Manivasagam, JCIT

Section 147Section 2(22)(e)

interest free loan-totaling to rs.2,99,25,000/-. This addition is strengthened by the fact that there had been no business / commercial expediency meriting these transactions. It is nothing but deemed dividend for the purpose of income tax assessment. Hence the same is added to the total income

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

ITA 2006/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2013-14

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 80ISection 92BSection 92C

deleted the transfer pricing adjustments made by the TPO. These decisions have not been reversed as of the date of this order. 4.9. Further, commercial expediency of the royalty transaction entered in to by the Appellant cannot be questioned. This position is supported by the judgment

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

ITA 2005/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2012-13

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 80ISection 92BSection 92C

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

Section 250

loan quotation obtained from Bank of Nova Scotia, Singapore at 6-month USD LIBOR + 2.60%. The assessee contended that the advances were made for commercial expediency, namely for facilitating product registration, marketing, and distribution infrastructure in foreign jurisdictions where the AEs were responsible for securing necessary regulatory approvals to market ... which emphasized that all international transactions with AEs must be benchmarked at Arm's Length Price (ALP), regardless of the commercial expediency claimed by the assessee. 7. The Authorised Representative (AR) of the assessee stated that the issue is covered by the decision of Co-ordinate Bench in assessee

SEVEN ENERGIES ODISHA LIMITED,HYDERABAD vs. ACIT CIRCLE 3(1), HYD, HYDERABAD

ITA 1518/HYD/2025[2016-17]Status: DisposedITAT Hyderabad20 Feb 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1518/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Seven Energies Odisha Vs. Acit, Limited, Circle-3(1), Hyderabad. Hyderabad. Pan: Aatcs5759E (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Sashank Dundu, Advocate राज" व "ारा/Revenue By: Ms. Aditi Goyal, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 05/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 07/02/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 18/12/2018 For The Assessment Year (Ay) 2016-17. The Assessee

For Appellant: Shri Sashank DunduFor Respondent: Ms. Aditi Goyal, Sr.AR

Section 143(3)Section 69

learned CIT(Appeals)/NFAC erred in disregarding material submissions, bank statements, audited financials, and documentary evidence filed during the assessment proceeding. which elucidate the commercial expediency and business context (works contract activity with temporary working capital investments). 2. The learned CIT (Appeals)/NFAC ought to have appreciated that the Appellant

DENTSU AEGIS NETWORK INDIA PRIVATE LIMITED(ERSTWHILE VIZEUM MEDIA SERVICE INDIA MERGED IN DAN INDIA),MUMBAI vs. INCOME TAX OFFICER, CIRCLE 8(3)(2), MUMBAI, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 6122/MUM/2025[2014-15]Status: DisposedITAT Mumbai20 Feb 2026AY 2014-15

Bench: Shri Rahul Chaudhary & Shri Makarand Vasant Mahadeokardentsu Aegis Network Dcit Central India Private Limited Circle-1(1), (Erstwhile Vizeum Media Vs. Aayakar Bhavan, Service India Merged Maharashi Karve With Dentsu Aegis Marg, Mumbai-400 Network India Private 020 Limited W.E.F. 1St April 2017) 2Nd Floor, Devchand House, Dr. A. B. Road, Shiv Sagar Estate Mumbai, Worli So, Mumbai-400 018 Pan/Gir No. Aahca3058N (Applicant) (Respondent) Assessee By Shri Ketan Ved & Shri Abdul Kadir Jawadwala, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 02.02.2026 Date Of Pronouncement 20.02.2026

Section 142(1)Section 143(3)Section 250Section 37(1)Section 40Section 40A(2)(b)

assessee could not identify specific personnel deputed exclusively for it. It was contended that, as explained in the submissions before the CIT(A), commercial expediency and business needs had to be judged from the standpoint of a prudent businessman and not from that of the Assessing Officer, and that

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