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“business expediency”

Business ExpensesSection 37Section 37849 judgments

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

Leading authorities on business 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. 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.

CIT v. Walchand & Co.
65 ITR 381 · 1967 · Supreme Court
314
citing judgments

The necessity and reasonableness of business expenditure, including the utilization of borrowed funds, must be judged from the perspective of a businessman based on commercial expediency, and cannot be dictated by revenue authorities. The onus is on the assessee to demonstrate the business purpose and commercial expediency.

Judgments citing business expediency

Urlife Lifestyle Wellness Limited, Hyderabad vs. Assistant Commissioner of Income-Tax, Corporate Circle 4(1), Chennai

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

ITA 2160/CHNY/2025[AY 2021-22]Status: DisposedITAT Chennai27 Nov 2025

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.: 2160/Chny/2025 िनधा"रण वष"/Assessment Year: 2021-22 Urlife Lifestyle Wellness The Assistant Commissioner Ltd., Vs. Of Income Tax, 2Nd Floor, Corporate Circle – 4(1), Apollo Health City, Chennai. Apollo Hospitals Complex, Jubilee Hills, Film Nagar, Hyderabad – 500 096. Pan: Aadca 8021H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri K. Abhiroop Bhargav, Ca ""यथ" क" ओर से/Respondent By : Ms. T. Mythili, Jcit सुनवाई क" तारीख/Date Of Hearing : 26.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 27.11.2025

For Appellant: Shri K. Abhiroop Bhargav, CAFor Respondent: Ms. T. Mythili, JCIT
Section 11Section 143(3)Section 250Section 37(1)

were made in form of consultancy expenses, parties either did not file reply or filed incomplete reply. Therefore, in the present case, since the business expediency of the expenses has not been established by the appellate, I am of the view that AO has rightly disallowed the consultancy expenses ... expenditure having no nexus to the business of the assessee. The FAA confirmed the disallowance made by the AO by observing that the business expediency of the expenses has not been established by the assessee. The assessee’s contention was that these payments were made through banking channels and requisite

Infres Methodex Private Limited, Delhi vs. Assistant Commissioner of Income Tax, Circle 12(1), Delhi

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

ITA 449/DEL/2025[2017-18]Status: DisposedITAT Delhi19 Nov 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2017-18] Infres Methodex Pvt. Ltd. Vs Acit Block-B-1, Plot No.D-7, Circle-12(1) Mohan Co-Operative Delhi Industrial Estate, Mathura Road, New Delhi-110044 Pan-Aabci1964R Appellant Respondent Assessee By Shri Rahul Kant, Ca Revenue By Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 19.11.2025 Date Of Pronouncement 19.11.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 28.11.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A), Delhi-4/10728/2019-20 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of The Assessment Order Dated 23.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Filed Its Return Of Income On 29.10.2017, Declaring Total Income At Inr 22,86,60,530/-. The Assessee Is Engaged In The Business Of Manufacturing & Marketing Of Currency Counting Machines & Verifiers & Paper Shredders Etc. The Case Of The Assessee Was Selected For Scrutiny & The Ao Has Made The Disallowance Of Inr 22,91,385/- U/S 14A Of The Act. Besides This, The Disallowance Of Inr 14,82,901/- Is Made Out Of Payment Made To Clubs & Inr 31,57,057/- Were Disallowed Out Of Travelling & Conveyance Expenses. The Ao Also Made Addition Of Inr 2,02,76,999/- On Account Of Custom Duty Paid By Holding The Same As Unexplained Expenditure.

Section 143(3)Section 14ASection 250Section 37Section 69C

normal business expenditure and incurred for purpose of business. As these expenses were incurred wholly and exclusively for the purpose of business under business expediency, it should be allowed as claimed. In this regard, reliance is placed on the following judgments:- (i) CIT(A) Order dated 23/10/2017 in Appeal

Assistant Commissioner of Income Tax, Panchkula Circle, Panchkula vs. Konark Rajhans Estate Private Limited, Panchkula

In the result, the appeal of the revenue stands dismissed

ITA 805/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh13 Nov 2025AY 2011-12

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 805/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2011-12 Acit M/S Konark Rajhans Estate Private Limited Panchkula Circle बनाम/ Vs. Nh 73, Village Kot Extension-Ii, Sector 14, Panchkula. Panchkula. "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaeck-2405-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Manav Bansal (Cit) – Ld. Dr ""थ"कीओरसे/Respondent By : Sh. Parikshit Aggarwal (Ca)-Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 20-08-2025 घोषणाकीतारीख /Date Of Pronouncement : 13/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeal By The Revenue For Assessment Year (Ay) 2011- 12 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 27-05-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) R.W.S. 147 Of The Act On 29-12-2018. The Revenue Is Aggrieved By Deletion Of Twin Quantum Additions Of Rs.40.85 Lacs & Rs.707.75 Lacs As Made By Ld. Ao In The Assessment Order. The Grounds Of Appeal Read As Under: -

For Appellant: Sh. Manav Bansal (CIT) – Ld. DRFor Respondent: Sh. Parikshit Aggarwal (CA)-Ld. AR
Section 131oSection 143(3)Section 148Section 40A(3)Section 68Section 68o

1 IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, CHANDIGARH PHYSICAL HEARING BEFORE HON’BLE SHRI RAJPAL YADAV, VICE PRESIDENT

Deputy Commissioner of Income Tax, Circle-1(1), Kolkata vs. Bandhan Financial Services Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 1139/KOL/2025[2014-15]Status: DisposedITAT Kolkata11 Nov 2025AY 2014-15

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2014-15 Dcit, Circle-1(1), Kolkata..……………… ……………...……….……….……Appellant Vs. Bandhan Financial Services Ltd....………………………….......……...…..…..Respondent Dn 32 Salt Lake, Salt Lake City, Sech Bhawan, S.O Salt Lake, Kol-700091. [Pan: Aabcg0611R] Appearances By: Shri Manas Mondal, Addl. Cit-Dr, Appeared On Behalf Of The Appellant. Shri Biswanath Paul, Fca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : November 11, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Revenue Is Directed Against The Order Dated 11.06.2024 Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2014–15. 2. The Appeal Has Been Filed By The Revenue With A Delay Of 56 Days. The Revenue Has Filed A Petition For Condonation Of The Delay. After Considering The Reasons Cited In The Petition For Condonation Of Delay, We Find That The Reasons Are Valid & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 139Section 143(2)Section 143(3)Section 250Section 37(1)Section 40A(3)

been taken in records of the company for submitting to the insurance company. The ld. AR further submitted that the loans was required for business expediency and the Assessing Officer allowed the disallowance of expenses in earlier years. The assessee during the course of assessment proceedings had inter alia submitted