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“commercial expediency”

Business ExpensesSection 37Section 371,685 judgments

The decision most relied on for commercial expediency is S.A. Builders Ltd. v. CIT (288 ITR 1), cited in 1,484 judgments on BharatTax.

Leading authorities on commercial expediency

S.A. Builders Ltd. v. CIT
288 ITR 1 · 2007 · Supreme Court
1,484
citing judgments

Interest paid on borrowed funds cannot be disallowed merely because the assessee made interest-free advances, provided those advances were made for business purposes and commercial expediency. The Revenue cannot dictate a businessman's commercial decisions, but the assessee bears the onus to prove the business expediency.

Empire Jute Co. Ltd. v. CIT
124 ITR 1 · 1980 · Supreme Court
622
citing judgments

Expenditure is classified as revenue or capital based on its practical business effect, necessity, or expediency, rather than solely on the juristic classification of rights; an enduring benefit does not automatically make an expenditure capital if it facilitates trading operations or business efficiency.

CIT v. Reliance Industries Ltd.
410 ITR 466 · 2019 · Supreme Court
501
citing judgments

When mixed funds are available, interest-free advances are presumed to be made from the assessee's own interest-free funds, preventing disallowance of interest expenditure under section 36(1)(iii). This principle also applies to section 14A disallowance, where interest expenditure is not disallowed if surplus funds are available and no direct nexus is established with borrowed funds for investments earning exempt income.

CIT v. Dalmia Cement (Bharat) Ltd.
254 ITR 377 · 2002 · High Court
417
citing judgments

When there is a nexus between an expenditure and the purpose of business, incurred on grounds of commercial expediency, the Revenue cannot question its reasonableness or assume the role of the businessman to compel profit maximization. This principle applies even if the business is not that of the assessee itself.

Hero Cycles Pvt. Ltd. v. CIT
379 ITR 347 · 2015 · Supreme Court
361
citing judgments

The Revenue cannot substitute its judgment for that of a businessman regarding the necessity or reasonableness of an expenditure. If an expense is incurred wholly and exclusively for business purposes, it is deductible, and the Revenue cannot question its commercial expediency.

CIT v. Abhishek Industries Ltd.
286 ITR 1 · 2006 · High Court
359
citing judgments

For interest on borrowed capital to be deductible under Section 36(1)(iii), there must be a nexus between the use of the borrowed funds and the purpose of the business. This decision has been overruled by the Supreme Court in Munjal Sales Corporation v. CIT (2008).

Eastern Investments Ltd. v. CIT
38 ITR 601 · 1960 · Supreme Court
346
citing judgments

Expenditure must be commercially expedient for carrying on the business, and it is not for revenue authorities to dictate how an assessee should conduct its business. The court will not question the business expediency of a transaction, even if a third party also benefits.

Sassoon J. David & Co. Pvt. Ltd. v. CIT
118 ITR 261 · 1979 · Supreme Court
323
citing judgments

An expense incurred by an assessee for its own business, such as advertising, marketing, and promotional (AMP) expenses, cannot be disallowed merely because it incidentally or indirectly benefits the assessee's sister concerns or associated enterprises.

Judgments citing commercial expediency

DCIT, New Delhi vs. M/S. Sahara India Commercial Corporation Ltd., Kolkata

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 2620/DEL/2013[2009-10]Status: DisposedITAT Delhi23 Dec 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

However, in the first-place onus is on the assessee to show that the interest- bearing funds were advanced for business purposes and for commercial expediency. Thus, in light of uncontroverted findings of the First Appellate Authority, we see no reason to interfere with findings of the CIT(A), hence

Sahara India, Kolkata vs. DCIT, New Delhi

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 1977/DEL/2013[2009-10]Status: DisposedITAT Delhi23 Dec 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

However, in the first-place onus is on the assessee to show that the interest- bearing funds were advanced for business purposes and for commercial expediency. Thus, in light of uncontroverted findings of the First Appellate Authority, we see no reason to interfere with findings of the CIT(A), hence

Assistant Commissioner of Income Tax, Central Circle, Dhanbad vs. Bindhyavasini Commercial Services Private Limited, Dhanbad

ITA 240/RAN/2023[2013-14]Status: DisposedITAT Ranchi22 Dec 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.240/Ran/2023 Assessment Year: 2013-14 Acit, Central Circle, Dhanbad.….……………............................……….……Appellant Vs. Bindhyavasini Commercial Services Pvt. Ltd….........……........……...…..…..Respondent House No.41, Premises Of Punj Kumar Singh, Near Suraksha Clinic, Hetli Bandh, Jharia, Dhanbad, Jharkhand – 828111. [Pan: Aaecb0160D] Appearances By: Shri Manish Tiwari, Ar, Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Cit Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 22, 2025

Section 131Section 133(6)Section 139(1)Section 143(2)Section 143(3)Section 250Section 68

Assessing Officer and in reply to the show cause notice, the assessee has explained that the rebate has been allowed in view of commercial expediency and none of the customers to whom rebate has been allowed have been found to be bogus and in this kind of business of liquor

The Brahmaling Multipurpose Co-Op Society Ltd, Belgaum vs. Income Tax Officer, Ward -3, Belgaum

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

ITA 254/PAN/2025[2017-18]Status: DisposedITAT Panaji22 Dec 2025AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Section 80PSection 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

Shri Anand Venkateshwara Developers, Pune vs. Income Tax Officer Ward 9(3), Pune

In the result, appeal of the assessee is allowed for statistical purpose

ITA 2407/PUN/2025[2013-14]Status: DisposedITAT Pune22 Dec 2025AY 2013-14

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2407/Pun/2025 निर्धारण वषा / Assessment Year: 2013-14 Shri Anand Venkateshwara V The Income Tax Officer, Developers, S Ward-9(3), Pune. S.No.23/2/1 B 5, S.No.23, H.No.2/1 B5, Anand Park, Thergaon Road, Pimpri, Pune – 411033. Maharashtra. Pan: Acnfs5707R Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas P Bora Revenue By Shri Harshit Bari – Addl.Cit(Virtual) Date Of Hearing 18/12/2025 Date Of Pronouncement 22/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 Dated 29.08.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Act, Dated 30.03.2022. The Assessee Has Raised The Following Grounds Of Appeal :

Section 139(1)Section 147Section 148Section 149Section 250Section 56

purpose of business by lending to sister concern on interest, which generated income for the appellant. b) The transaction was on account of commercial expediency as the same were advanced to the sister concern on interest to safeguard business interest and generate income. c) The interest earned from sister concern

M/S. Indus Trust, Bengaluru vs. ACIT, Circle-2(2)(1), Bengaluru

ITA 2298/BANG/2024[2012-13]Status: DisposedITAT Bangalore19 Dec 2025AY 2012-13

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri Balusamy N, JCIT
Section 234B

However, the said amount was disallowed by the AO in the assessment order by the AO by holding that said payment does not carry commercial expediency. 5. The aggrieved assessee preferred an appeal before the learned CIT(A). 6. The assessee before the learned CIT(A) submitted that ... erred in disallowing the sum of ₹50,89,000/- by merely describing it as "donation" and holding that the same lacked commercial expediency. The assessee clarified that the amount was not a voluntary or gratuitous donation, but was paid to Indus Charity, which was running a school for economically poor

Assistant Commissioner of Income Tax, New Delhi vs. Jaipur Golden Transport Co Private Limited, New Delhi

In the result, appeal of the Revenue is partly allowed

ITA 4990/DEL/2024[2012-13]Status: DisposedITAT Delhi19 Dec 2025AY 2012-13

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year:2012-13] Assistant Commissioner, Of Jaipur Golden Transport Co. Income Tax, Private Limited, Room No.316A, C.R. Vs 4741, Roshananra Road, Building, I.P Estate, Malkaganj, North Delhi, New New Delhi-110002 Delhi-110007 Pan Aaacj4124B Appellant Respondent Revenue By Shri Om Prakash, Sr. Dr Assessee By Shri Y.K. Mehan, Ca, Shri Dheeraj Kumar, Ca Date Of Hearing 11.12.2025 Date Of Pronouncement 19.12.2025

Section 143(3)

consequently concluded that the results of his enquiries alluded towards an element of claimed expenses being unverified, lacking Page 3 of 12 commercial expediency and excessive and hence proceeded to make additions on the basis of his surmises. 5. Before the ld. CIT(A), the assessee reiterated the arguments taken ... rescue of ld. First Appellate Authority. 9. We have noted that the assessee is engaged in the business of transport, where the commercial expediency of claimed expenses cannot be all together ruled out. At the same time, it is a settled principle of law that the expenses claimed in course

Reddy Housing Private Limited, Bengaluru vs. Income Tax Officer, Ward-5(1)(4), Bengaluru

In the result, appeal of the assessee is allowed for statistical purposes

ITA 635/BANG/2025[2016-17]Status: DisposedITAT Bangalore18 Dec 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2016-17 M/S. Reddy Housing Pvt. Ltd., Vs. Ito, #133/1 The Residency, 2Nd Floor Ward - 2, Residency Road, Hassan. H No.36B, Bommegowda Building, Paduvalu, Hippe Holenarasipur, Hassan– 573 211, Karnataka. Pan : Bsops 2078 N Appellant Respondent Assessee By : Smt. Narendra Sharma Adv Revenue By : Shri. Balusamy N, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 12.11.2025 Date Of Pronouncement : 18.12.2025

For Appellant: Smt. Narendra Sharma AdvFor Respondent: Shri. Balusamy N, JCIT(DR)(ITAT), Bangalore
Section 142(1)Section 143(2)Section 2(22)(e)Section 36(1)(iii)

submissions. Secondly, only because the funds have been provided to the holding company/related companies, does not automatically lead to the inference that there is commercial expediency. Whether or not there was commercial expediency or not is a matter of fact which depends on the facts of each and every case ... Chandigarh reported in [2007] 158 Taxman 74 (SC) and further submitted that if the loans and advances are given for commercial expediency no addition can be made under section 36(1)(iii) of the Act. 7. On the other hand, learned DR relied on the Order of lower authorities

Instakart Services Private Limited, Bangalore vs. ACIT, Special Range-3, Bangalore

In the result appeal of the Revenue is hereby dismissed

ITA 544/BANG/2025[2017-18]Status: DisposedITAT Bangalore18 Dec 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Vohra, Sr. Advocate and Ms. AnkitaFor Respondent: Shri Shivanad Kalakeri, CIT

Therefore, the losses incurred in the initial years, arising from the assessee’s strategy to expand operations and win customers, are on account of commercial expediency and cannot be disallowed. 8.6 Further, the AO has erred in indirectly bringing notional profits to tax by disallowing genuine business losses by treating ... deleted, as the loss was incurred in the genuine course of business which is incidental to the trade, and is supported both by commercial expediency and by settled judicial principles. 9. However, the learned CIT(A) after considering the facts in totality rejected the argument advanced by the assessee

Instakart Services Private Limited, Bangalore vs. JCIT, Special Rang-3, Bangalore

In the result appeal of the Revenue is hereby dismissed

ITA 543/BANG/2025[2016-17]Status: DisposedITAT Bangalore18 Dec 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

Therefore, the losses incurred in the initial years, arising from the assessee’s strategy to expand operations and win customers, are on account of commercial expediency and cannot be disallowed. 8.6 Further, the AO has erred in indirectly bringing notional profits to tax by disallowing genuine business losses by treating ... deleted, as the loss was incurred in the genuine course of business which is incidental to the trade, and is supported both by commercial expediency and by settled judicial principles. 9. However, the learned CIT(A) after considering the facts in totality rejected the argument advanced by the assessee

DCIT CC -1(4), Bengaluru vs. Instakart Services Pvt Ltd, Bengaluru

In the result appeal of the Revenue is hereby dismissed

ITA 531/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

Therefore, the losses incurred in the initial years, arising from the assessee’s strategy to expand operations and win customers, are on account of commercial expediency and cannot be disallowed. 8.6 Further, the AO has erred in indirectly bringing notional profits to tax by disallowing genuine business losses by treating ... deleted, as the loss was incurred in the genuine course of business which is incidental to the trade, and is supported both by commercial expediency and by settled judicial principles. 9. However, the learned CIT(A) after considering the facts in totality rejected the argument advanced by the assessee

DCIT, CC-1(4), Bengaluru vs. Instakart Services Pvt Ltd, Bengaluru

In the result appeal of the Revenue is hereby dismissed

ITA 530/BANG/2025[2017-18]Status: DisposedITAT Bangalore18 Dec 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

Therefore, the losses incurred in the initial years, arising from the assessee’s strategy to expand operations and win customers, are on account of commercial expediency and cannot be disallowed. 8.6 Further, the AO has erred in indirectly bringing notional profits to tax by disallowing genuine business losses by treating ... deleted, as the loss was incurred in the genuine course of business which is incidental to the trade, and is supported both by commercial expediency and by settled judicial principles. 9. However, the learned CIT(A) after considering the facts in totality rejected the argument advanced by the assessee

Instakart Services Private Limited, Bengaluru vs. ACIT, Central Circle-1(4), Bengaluru

In the result appeal of the Revenue is hereby dismissed

ITA 496/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

Therefore, the losses incurred in the initial years, arising from the assessee’s strategy to expand operations and win customers, are on account of commercial expediency and cannot be disallowed. 8.6 Further, the AO has erred in indirectly bringing notional profits to tax by disallowing genuine business losses by treating ... deleted, as the loss was incurred in the genuine course of business which is incidental to the trade, and is supported both by commercial expediency and by settled judicial principles. 9. However, the learned CIT(A) after considering the facts in totality rejected the argument advanced by the assessee

ACIT Circle 3(2)(1), Mumbai vs. Sip Infotech Limited, Mumbai

Accordingly it should be disallowed

ITA 5917/MUM/2025[2019-20]Status: DisposedITAT Mumbai17 Dec 2025AY 2019-20

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavacit, Circle-3(2)(1), Room No. 608, 6Th Floor, Aayakar Bhavan, M.K.Road, Churchgate, Mumbai-400020. (Appellant)

For Appellant: Shri K. Gopal &For Respondent: Shri Brajendra Kumar, Sr.DR
Section 132Section 147Section 148Section 270ASection 37Section 37(1)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “SMC” BENCH : MUMBAI BEFORE JUSTICE (RETD.) SHRI C.V. BHADANG, PRESIDENT AND SHRI VIKRAM

ACIT, Mumbai vs. Reliance Power Ltd, Mumbai

ITA 3989/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Dec 2025AY 2016-17

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am Acit-15(3)(1), Aayakar Bhavan, Room No. 460, 4Th Floor, M.K. Road, Mumbai-400020. Vs. Revenue-अपीलार्थी / Appellant Assessee By Revenue By Date Of Hearing Date Of Pronouncement

Section 115JSection 14Section 143(3)Section 14ASection 37(1)

fair proportionate part thereof. In this regard, the appellant has claimed that the investments made by it are for the purpose of commercial expediency and for the purposes of advancing/furtherance of its power business interest only, since the investments have been made into its subsidiary companies which are into ... made on account of business expediency to wrest control over the companies. In this regard, the appellant has relied upon the concept of “commercial expediency” used by Hon'ble Supreme Court in the case of S.A. Builders (158 Taxmann.com 74(SC). Thus, the appellant has claimed that these transactions

Assistant Commissioner of Income Tax, Circle-1, Dibrugarh vs. Greenply Industries Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 140/GTY/2024[2013-14]Status: DisposedITAT Guwahati15 Dec 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shrimanomohan Das, Jm Greenply Industries Ltd Acit, Circle-1 Madgul Lounge, 5 Th Floor, 23 Aaykar Bhawan, Milan Nagar, Chetiacental Road, Kolkata- Vs. Dibrugarh-786001, Assam 700027, West Bengal (Appellant) (Respondent) Pan No. Aaacg7284R Assessee By : Shri Ashok Tulsyan, Ar Revenue By : Shri Sanjay Jha, Dr Date Of Hearing: 02.12.2025 Date Of Pronouncement: 15.12.2025

For Appellant: Shri Ashok Tulsyan, ARFor Respondent: Shri Sanjay Jha, DR
Section 115J

adopted by the assessee with specific intention or motive and the case has been sought to be made out merely on the basis of commercial expediency by claiming that the assessee was benefited as a result of giving the guarantees in the form of commercial benefits secured for future ... opinion, such commercial expediency cannot be equated with business strategy, which is specific and well laid out. As rightly held by the Id. CIT(A), a financial loan guarantee is a commitment entered into by the assessee company with a third party lender of its Associated Enterprises which obliges

DCIT, Circle-1 & Tps, Hubballi vs. Hubli Scan Centre Pvt. Ltd., Dharwad

In the result the grounds raised by the learned assessing officer are allowed as indicated above

ITA 554/BANG/2025[2018]Status: DisposedITAT Bangalore15 Dec 2025

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubeyassessment Year : 2018-19 M/S. Hubli Scan Centre Pvt. The Deputy Commissioner Ltd., Of Income Tax, 6-13 Lgf, Eureka Junction, Circle-1 & Tps, Travelers Bungalow Road Vs. Hubballi Dharwad - 580029 Pan: Aaach9520M Appellant Respondent

For Appellant: Shri Chytanya V Mudrabettu, Advocate
Section 143(3)Section 37(1)

Assessee became free and therefore said deposit was written off and claimed as deduction u/s. 37(1) as business expenditure or loss based on commercial expediency. In paragraph no. 3.3, the Assessing Officer reiterated the settlement agreement and thereafter held that the contention of the Assessee on the issue ... Writing off of the deposit is not remote or illusory just because of the related party matter between both the companies. As the commercial expediency must be decided from the businessman point of view, Hubli Scan Centre Ltd written off Non- recoverable deposit as a business loss under section

Karnataka Housing Board, Bangalore vs. DCIT, Exemptions, Circle-1, Bangalore

ITA 512/BANG/2025[2021-22]Status: DisposedITAT Bangalore15 Dec 2025AY 2021-22

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

For Appellant: Sri Padamchand Khincha, A.RFor Respondent: Sri K.M. Mahesh, D.R
Section 10Section 11Section 13(8)Section 143(2)Section 2(15)Section 234ASection 250

ITA Nos.512 & 513/Bang/2025 Karnataka Housing Board, Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL "A" BENCH: BANGALORE BEFORE SHRI LAXMI PRASAD

Kasturi Medical Centre Private Limited, Joka, Thakurpukur vs. Additional/Joint/Deputy/Assisstant Commissioner of Income Tax/Income-Tax Officer, Delhi

In the result the appeal of the assessee is allowed

ITA 318/KOL/2025[2018-19]Status: DisposedITAT Kolkata12 Dec 2025AY 2018-19

Bench: Shri Manunatha G & Shri Sonjoy Sarmai.T.A. No.318/Kol/2025 Assessment Year: 2018-19 Kasturi Medical Centre Pvt. Ltd……………….................................……….…Appellant 5, Diamond Harbour Road, 3A Bus Stand, Joka, Thakurpukur, W.B – 700104. [Pan: Aacck1872F] Vs. Acit, Nfac, Delhi…….…………..…………….…..….......……..…...…..…..Respondent Appearances By: Shri Indernil Banerjee, Fca, Appeared On Behalf Of The Revenue. Shri Soumitra Ghosh, Sr. Dr, Appeared On Behalf Of The Assessee. Date Of Concluding The Hearing : September 16, 2025 Date Of Pronouncing The Order : December 12, 2025 Order Per Sonjoy Sarma: This Appeal Is Filed By The Assessee Against The Order Of The Learned Cit(A) Passed For The Assessment Year 2018–19, Whereby The Addition Of ₹85,40,911 Made By The Assessing Officer On Estimated Basis After Rejection Of Books Of Account Under Section 145(3) Of The Income-Tax Act, 1961 Was Confirmed. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For Ay 2018–19 Declaring Total Income Of ₹2,05,59,220. The Case Was Selected For Complete Scrutiny Under The Scrutiny Assessment Scheme, 2019, Primarily On The Issue Of Large Refund Claimed Out Of Advance Tax. Accordingly, Notices Under Section 143(2) & Section 142(1) Of The Act Along With Questionnaires Were Duly Issued & Served.

Section 142(1)Section 143(2)Section 145(3)

Once business expediency and genuineness are established, the Department cannot question the wisdom of the expenditure. The AR relied on settled principles that commercial expediency is to be judged from the assessee’s perspective, and estimation without rejection of specific defects is invalid. 4.1 The ld. AR submitted that

Srf Limited, Delhi vs. Assistant / Deputy Commissioner of Income Tax, Circle 10(1), New Delhi, Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 5618/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

further submitted that no adjustment is required when it is reimbursement of expenses. He further submitted that transactions were undertaken from commercial expediency point of view and were not intended for the exploitation of return. He thereafter submitted that Co-ordinate Bench of Tribunal in the case of Vedanta