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“business expediency”

Business ExpensesSection 37Section 37849 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)

Appellant and also failed to consider the documentary evidence and explanation provided vide various submissions during the course of appellate/assessment proceedings substantiating the business expediency of incurring such expenses. 2.4. On the facts and in the circumstances of the case

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

directors and key managerial personnel, we find that there is nothing placed on record to demonstrate that such advances were made out of commercial business expediency. The assessee has not produced any material to establish that such advances were in furtherance of the business interests of the assessee

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

directors and key managerial personnel, we find that there is nothing placed on record to demonstrate that such advances were made out of commercial business expediency. The assessee has not produced any material to establish that such advances were in furtherance of the business interests of the assessee

NOBEL AUTOMOTIVE INDIA PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CORP CIRCLE 4(1), CHENNAI

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

ITA 2009/CHNY/2025[2022-23]Status: DisposedITAT Chennai09 Mar 2026AY 2022-23

Bench: Shri Aby T Varkey & Shri S.R. Raghunatha

For Appellant: Shri. Bipin C.N, CITFor Respondent: 19.01.2026
Section 143(3)Section 40

evidence. Since relevant documents have now been produced which go to the root of the matter, the issue requires verification of the genuineness and business expediency of the expenditure. In the absence of such verification, a conclusive finding cannot be rendered at this stage. :-5-: ITA No.2009/Chny/2025 12. As regards

SHREE GANESH BUILDERS LTD.,NAGPUR vs. DCIT, CIRCLE 1, NAGPUR

ITA 626/NAG/2024[2014-15]Status: DisposedITAT Nagpur24 Feb 2026AY 2014-15

Bench: Shri Pawan Singh, Jm & Shri Khettra Mohan Roy, Am

For Appellant: Shri Himesh Demble, CAFor Respondent: Shri Surjit Kumar Saha
Section 143(3)Section 40A(3)

paid by other than by account payee cheques, only on request of the vendor. The cash payment was only looking to the business expediency. The parties from whom the assessee had purchased agricultural land are farmers and mainly resident of village and at time they need some cash. Looking ... business expediency and other relevant factors the assessee company has no option but to make the payment in cash as per their request, otherwise, there is all possibility the assessee company may loose the land transaction. During the course of assessment proceeding the learned A.O. has asked to the assessee

SHREE GANESH BUILDERS LTD.,NAGPUR vs. DCIT, CIRCLE 1, NAGPUR

ITA 625/NAG/2024[2013-14]Status: DisposedITAT Nagpur24 Feb 2026AY 2013-14

Bench: Shri Pawan Singh, Jm & Shri Khettra Mohan Roy, Am

For Appellant: Shri Himesh Demble, CAFor Respondent: Shri Surjit Kumar Saha
Section 143(3)Section 40A(3)

paid by other than by account payee cheques, only on request of the vendor. The cash payment was only looking to the business expediency. The parties from whom the assessee had purchased agricultural land are farmers and mainly resident of village and at time they need some cash. Looking ... business expediency and other relevant factors the assessee company has no option but to make the payment in cash as per their request, otherwise, there is all possibility the assessee company may loose the land transaction. During the course of assessment proceeding the learned A.O. has asked to the assessee

MAHENDRAKUMAR DANMAL MUTHA,MUMBAI vs. INCOME TAX OFFICER 19(2)(2), MUMBAI

In the result, the appeal of the assessee is partly allowed in\nterms indicated hereinabove

ITA 7590/MUM/2025[2010-11]Status: DisposedITAT Mumbai19 Feb 2026AY 2010-11
Section 133(6)Section 250

total income.\n9. The Assessing Officer also disallowed commission expenses\nof Rs. 14,18,330/- holding that the assessee had failed to\nestablish business expediency and genuineness of the payments.\nAccordingly, the assessment was completed under section 143(3)\nat a total income of Rs. 59,19,533/- as against ... goods and\nhad not furnished satisfactory evidence regarding delivery of\ngoods. The CIT(A) further held that the assessee had failed to\nestablish business expediency in respect of commission\nexpenditure of Rs. 14,18,330/-. Accordingly, the CIT(A) confirmed\nthe addition of Rs. 34,08,966/- towards non-genuine

M/S.RUNWAL COMMERCIAL ASSETS PVT LTD (NOW MERGED WITH WHEELABRATOR ALLOY CASTINGS LIMITED),MUMBAI vs. THE INCOME TAX OFFICER, WARD 15(3)(1), MUMBAI, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 7623/MUM/2025[2023-24]Status: DisposedITAT Mumbai18 Feb 2026AY 2023-24

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Runwal Commercial Ito Ward-15(3)(1), Assets Pvt. Ltd. (Now Aayakar Bhavan, Merged With Vs. Maharshi Karve Wheelabrator Alloy Road, New Marine Castings Limited) Lines, Churchgate, Runwal & Omkar Mumbai-400 020 Esquires, 4Th Floor, Off Eastern Exp. Highway Opp. Sion Chuan Bhatti Signal, Sion East, Mumbai-400 022 Pan/Gir No. Aajcr7366J (Applicant) (Respondent) Assessee By Shri Rakesh Joshi, Ld. Ar Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 18.02.2026

Section 115BSection 143(3)Section 144BSection 250Section 68

question the wisdom of the assessee’s commercial decision. In CIT v. Dalmia Cement (Bharat) Ltd. (254 ITR 377) (Del), it was held that business expediency is to be judged from the perspective of the assessee and not the Revenue. 23. Applying the above principles to the present case

ACIT CENTRAL CIRCLE-1 RAIPUR, RAIPUR vs. MARUTI CLEAN COAL AND POWER LIMITED, RAIPUR

In the result, appeal of the Revenue in ITA No

ITA 558/RPR/2025[2016-17]Status: DisposedITAT Raipur16 Feb 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. /It(Ss)A No.19/Rpr/2025 Co No.19/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 The Assistant Commissioner Of Income Tax, Central Circle-1, Raipur (C.G.) ........अपीलाथ" / Appellant बनाम / V/S. Maruti Clean Coal & Power Limited 8Th Floor, Cbd Complex, Sector-21, Atal Nagar, Naya Raipur, Raipur-492 018 Pan: Aadcm4810C ……""यथ" / Respondent

For Appellant: S/shri Salil Kapoor &For Respondent: Shri Yogesh Kumar Sharma, CIT-DR

commission and other selling charges, expenses, repairs and maintenance and travelling and conveyance expenses Whether since Assessing Officer had not examined any aspect of business expediency and merely on ad hoc basis made disallowance without putting forward any specific such ad hoc disallowance was not in conformity with principles making

ARJUN KESHAVA MURTHY PERIKAL,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(3)(1), BENGALURU

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

ITA 810/BANG/2025[2016-17]Status: DisposedITAT Bangalore12 Feb 2026AY 2016-17
Section 142(1)

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n'SMC' BENCH, BANGALORE\nBEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND\nSHRI

DEPUTY COMMISSIONER OF INCOME TAX , CHENNAI vs. M/S. CHEMPLAST SANMAR LIMITED, CHENNAI

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

ITA 2627/CHNY/2025[2017-18]Status: DisposedITAT Chennai06 Feb 2026AY 2017-18

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 2627/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of Chemplast Sanmar Limited, Income Tax, Vs. 9, Cathedral Road, Non-Corporate Circle 8, Chennai - 600 086. Chennai Pan: Aaacc 3000F (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. Gouthami Manivasagam, Addl.Cit ""यथ" क" ओर से/Respondent By : Shri R. Vijayaraghavan, Advocate सुनवाई क" तारीख/Date Of Hearing : 03.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 06.02.2026

For Appellant: Ms. Gouthami ManivasagamFor Respondent: Shri R. Vijayaraghavan, Advocate
Section 115JSection 143(3)Section 14ASection 40A(7)Section 40A(7)(b)Section 40A(9)Section 43B

whether the expenses in question is governed by the provisions of section 135 of Companies Act, 2013 or the expenditure was incurred out of business expediency, we are of the view the matter requires to be remanded to the file of the AO for verification of the claim

ACITLTU-2, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

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

ITA 945/CHNY/2018[2009-10]Status: DisposedITAT Chennai05 Feb 2026AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.895/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 Ashok Leyland Limited, Vs. The Deputy Commissioner Of 1, Sardar Patel Road, Guindy, Income Tax, Chennai 600 032. Company Circle – Ltu, Chennai. [Pan: Aaaca4651L] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.945/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 The Assistant Commissioner Of Vs. Ashok Leyland Limited, Income Tax, 1, Sardar Patel Road, Guindy, Large Taxpayer Unit – 2, Chennai. Chennai 600 032. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Assessee By : Shri Vikram Vijayaraghavan, Advocate (Virtual) ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Cit सुनवाई की तारीख/ Date Of Hearing : 10.11.2025 घोषणा की तारीख /Date Of Pronouncement : 05.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Cross Appeals Filed By The Assessee & The Revenue Are Directed Against The Order Dated 28.12.2017 Passed By The Ld.

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri AR V Sreenivasan, CIT

premises. Furthermore, the said Circular does not restrict the benefit only if the accommodation is provided to all the employees, which, obviously, is a business expediency and it is not for the Assessing Officer to sit in the arm chair of the assessee to decide as what would be best

ASHOK LEYLAND LIMITED,CHENNAI vs. DCIT COMPANY CIRCLE 1 (1), CHENNAI

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

ITA 895/CHNY/2018[2009-10]Status: DisposedITAT Chennai05 Feb 2026AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.895/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 Ashok Leyland Limited, Vs. The Deputy Commissioner Of 1, Sardar Patel Road, Guindy, Income Tax, Chennai 600 032. Company Circle – Ltu, Chennai. [Pan: Aaaca4651L] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.945/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 The Assistant Commissioner Of Vs. Ashok Leyland Limited, Income Tax, 1, Sardar Patel Road, Guindy, Large Taxpayer Unit – 2, Chennai. Chennai 600 032. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Assessee By : Shri Vikram Vijayaraghavan, Advocate (Virtual) ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Cit सुनवाई की तारीख/ Date Of Hearing : 10.11.2025 घोषणा की तारीख /Date Of Pronouncement : 05.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Cross Appeals Filed By The Assessee & The Revenue Are Directed Against The Order Dated 28.12.2017 Passed By The Ld.

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri AR V Sreenivasan, CIT

premises. Furthermore, the said Circular does not restrict the benefit only if the accommodation is provided to all the employees, which, obviously, is a business expediency and it is not for the Assessing Officer to sit in the arm chair of the assessee to decide as what would be best

LIBERTY SHOES LTD,LIBERTY PURAM G.T.KARNAL ROAD KUTAIL DISTT KARNAL vs. PCIT ROHTAK HARYANA, DCIT KARNAL HARYANA

In the result, the appeal of the assessee is allowed

ITA 2206/DEL/2025[2020-21]Status: DisposedITAT Delhi29 Jan 2026AY 2020-21
Section 143(3)Section 14ASection 263

financial obligations\nand the AO has failed to examine the details with regard to the\ninterest paid on such loans vis-a-vis its business expediency and the\njustification of the loans taken. The assessee has filed a detailed\nsubmissions and after considering the submissions made, ld. PCIT\nin terms

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-25(1), NEW DELHI, DELHI vs. TECHNO TREXIM INDIA PVT. LTD., DELHI

In the result, appeal filed by the assessee is dismissed

ITA 582/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Jan 2026AY 2016-17
For Appellant: Shri I.P. Bansal, AdvocateFor Respondent: Shri Abhijeet Kumar, Sr.DR
Section 37

that the transfer of investment to the\nother sister concern with Nil sale consideration, whether the same be\nconsidered towards business expediency, we observed that the assessee\nhad planned the restructuring of the group concern with the concept of\nholding company in order to consolidate the resources, with this purpose ... carried on by the assessee are\nplanned within the four corners of the law and consolidation of the\nshareholding falls within the ambit of business expediency as held in the\ncase of S. A Builders (supra). After considering the financial statement,\nnothing has changed during the year under consideration

TECHNO TREXIM (INDIA) PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE- 25(1), DELHI, DELHI

In the result, appeal filed by the assessee is dismissed

ITA 468/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Jan 2026AY 2016-17
For Appellant: Shri I.P. Bansal, AdvocateFor Respondent: Shri Abhijeet Kumar, Sr.DR
Section 37

that the transfer of investment to the\nother sister concern with Nil sale consideration, whether the same be\nconsidered towards business expediency, we observed that the assessee\nhad planned the restructuring of the group concern with the concept of\nholding company in order to consolidate the resources, with this purpose ... carried on by the assessee are\nplanned within the four corners of the law and consolidation of the\nshareholding falls within the ambit of business expediency as held in the\ncase of S. A Builders (supra). After considering the financial statement,\nnothing has changed during the year under consideration

RAJA PAINTS INDIA PRIVATE LIMITED,GURGAON vs. DEPUTY COMMISSIONER OF INCOME TAX, GURGAON

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

ITA 5142/DEL/2025[2017-18]Status: DisposedITAT Delhi15 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2017-18] Raja Paints India Private Limited, Deputy Commissioner Of Income Scf-18 Sector-12A, Tax, Vanijya Nikunj, Shankar Chowk Grugaon, Haryana-122016 Vs Road, Phase-V, Udyog Vihar, Sector-19, Gurgaon, Haryana-122016 Pan-Aafcr2369J Assessee Revenue Assessee By Ms. Kavita Gupta, Ca Revenue By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 15.01.2026 Date Of Pronouncement 15.01.2026

Section 133ASection 143(3)Section 145Section 270A

availability of any explanation on the behalf of the assessee, the GP rate of the assessee is increased to 12% (after understanding the business expediency of the assessee), and after rejecting the GP rate of 2.998% shown by the assessee. This increase in the GP rate results in an addition

WAANEEP SOLAR PRIVATE LIMITED,DELHI vs. CENTRAL CIRCLE 2(4) , MUMBAI

ITA 4032/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Jan 2026AY 2016-17
For Appellant: Shri Rushabh Mehta, ARFor Respondent: Shri Arun Kanti Datta, (CIT-DR)
Section 132Section 153CSection 292CSection 69C

documentary evidence on the application of cash withdrawn from the\nbanks towards purchase of these lands. The assessee also could not\nestablish the business expediency of such large scale cash purchase of\nlands. Moreover, had the cash withdrawn been accounted and trailed\nperfectly, the complete amount

WAANEEP SOLAR PRIVATE LIMITED,DELHI vs. CENTRAL CIRCLE 2(4), MUMBAI

In the result, both the appeals of the assessee in ITA No

ITA 4031/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Jan 2026AY 2015-16
For Appellant: \nShri Rushabh Mehta, ARFor Respondent: \nShri Arun Kanti Datta, (CIT-DR)
Section 132Section 153CSection 292CSection 69C

documentary evidence on the application of cash withdrawn from the\nbanks towards purchase of these lands. The assessee also could not\nestablish the business expediency of such large scale cash purchase of\nlands. Moreover, had the cash withdrawn been accounted and trailed\nperfectly, the complete amount

M/S ASHAPURA DEVELOPERS ,MUMBAI vs. ACIT CIRCLE 1, THANE, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 5795/MUM/2025[2014-15]Status: DisposedITAT Mumbai08 Jan 2026AY 2014-15
Section 250Section 271(1)(c)Section 36(1)(iii)Section 68

free advances during the\nyear was only Rs. 64,17,245/-.\n7.\nHowever, the learned CIT(A) held that the assessee failed to\ndemonstrate business expediency in respect of the fresh interest-\nfree advances to the extent of Rs. 64,17,245/-. Accordingly, the\ndisallowance under section ... interest calculated at 12 percent on the\nincremental advances of Rs. 64,17,245/-, on the sole reasoning\nthat the assessee failed to demonstrate business expediency in\nrespect of such advances. In support, reliance was placed on\nparagraph 6.8 of the appellate order, wherein the learned CIT(A)\nobserved that

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