wholly and exclusively for business — 265 judgments | BharatTax

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)

detailed justification of services rendered by the group entity and the basis of cost allocation charged to the Appellant, which were incurred wholly and exclusively for business purposes. 2.3. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) / Ld. AO erred

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

ITA 3533/DEL/2025[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 143(1)Section 143(3)Section 263Section 40A(2)

relation to platform selling fees to ASSPL and claimed deduction under section 37 of the Act since the expense was incurred wholly and exclusively for business. 42. It is further submitted that the aforesaid expense was explicitly disclosed in Note 23 of the audited financial statement of the appellant

BOMBAY MINERALS LIMITED,KHAMBHALIA vs. DCIT, CENTRAL CIRCLE 3(3), MUMBAI

In the result, appeal of the Revenue

ITA 5410/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Gaurang R. Sanghavi (Virtually appeared)

Section 143(3)Section 14ASection 36(1)(iii)

represents an "outgo" incurred wholly and exclusively for Crores represents an "outgo" incurred wholly and exclusively for Crores represents an "outgo" incurred wholly and exclusively for business purposes. Although the Ld. CIT(A) mistakenly cited s purposes. Although the Ld. CIT(A) mistakenly cited s purposes. Although

DY. COMMISSIONER OF INCOME TAX, CENTRAL CICLE-3(3), MUMBAI, MUMBAI vs. BOMBAY MINERALS LIMITED, GUJARAT

In the result, appeal of the Revenue

ITA 5409/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Gaurang R. Sanghavi (Virtually appeared)

Section 143(3)Section 14ASection 36(1)(iii)

represents an "outgo" incurred wholly and exclusively for Crores represents an "outgo" incurred wholly and exclusively for Crores represents an "outgo" incurred wholly and exclusively for business purposes. Although the Ld. CIT(A) mistakenly cited s purposes. Although the Ld. CIT(A) mistakenly cited s purposes. Although

M/S. KAMAKSHI JUTE INDUSTRIES LIMITED,KOLKATA vs. ACIT, CIRCLE 1(1),, KOLKATA

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

ITA 3151/KOL/2025[2017-2018]Status: DisposedITAT Kolkata10 Mar 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115JSection 143(2)Section 143(3)Section 2(24)(x)Section 250Section 36(1)(va)

addition of Rs. 7,945/- made by the Ld. A.O. on account of interest on TDS even though the same was made wholly and exclusively for business purpose. 4. That the appellant craves leave to add, alter, modify, amend, delete and/or withdraw any or all of the grounds of appeal

IMRAN SIDDIQUI ,MYSORE vs. INCOME TAX OFFICER, WARD-2(2) , MYSORE

In the result, the appeal of the assessee id hereby allowed for statistical purposes

ITA 2238/BANG/2025[2014-15]Status: DisposedITAT Bangalore05 Mar 2026AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2014-15

For Appellant: Shri Tarun Kothari, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 131Section 250Section 44A

identifying specific defects in the claim. The . Page 7 of 8 assessee, on the other hand, contends that the expenditure was incurred wholly and exclusively for business purposes. This aspect also requires verification of supporting documents and a reasoned finding. 14.3 Considering the totality of the facts

VIMAL TRADING COMPANY,MADURAI vs. NON CORPORATE CIRLE - 1, MADURAI

In the result, the appeal of the assessee is allowed

ITA 2958/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Mar 2026AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2958/Chny/2025 िनधा$रण वष$ /Assessment Year: 2018-19

For Appellant: Mr. R. Venkata Raman, C.A ()For Respondent: Mr. R. Anitha, Addl. CIT

Section 250Section 37(1)

scheme followed by the appellant. 3. That the Ld. CIT(A) has failed to appreciate that all sales promotion expenses were incurred wholly and exclusively for business purposes, are supported by verifiable bank payments, and pertain fully to the relevant year, and hence are allowable under Section

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 4321/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR

Section 1

business. The said expenses mainly consisted of salary to its employees, professional fees and certain other expenses. These transactions were incurred wholly and exclusively for business purpose. Ld. Assessing Officer treated such transactions as non-genuine and disallowed the expenses u/s 37(1) of the Act. During the assessment proceedings

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 4320/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR

Section 1

business. The said expenses mainly consisted of salary to its employees, professional fees and certain other expenses. These transactions were incurred wholly and exclusively for business purpose. Ld. Assessing Officer treated such transactions as non-genuine and disallowed the expenses u/s 37(1) of the Act. During the assessment proceedings

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 4319/MUM/2025[2019-20]Status: DisposedITAT Mumbai20 Feb 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR

Section 1

business. The said expenses mainly consisted of salary to its employees, professional fees and certain other expenses. These transactions were incurred wholly and exclusively for business purpose. Ld. Assessing Officer treated such transactions as non-genuine and disallowed the expenses u/s 37(1) of the Act. During the assessment proceedings

ACIT, CC-6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 4318/MUM/2025[2022-23]Status: DisposedITAT Mumbai20 Feb 2026AY 2022-23

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR

Section 1

business. The said expenses mainly consisted of salary to its employees, professional fees and certain other expenses. These transactions were incurred wholly and exclusively for business purpose. Ld. Assessing Officer treated such transactions as non-genuine and disallowed the expenses u/s 37(1) of the Act. During the assessment proceedings

OVERSEAS INFRASTRUCTURE ALLIANCE(INDIA) PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -6 , MUMBAI

In the result, appeal by the assessee is allowed

ITA 4045/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR

Section 1

business. The said expenses mainly consisted of salary to its employees, professional fees and certain other expenses. These transactions were incurred wholly and exclusively for business purpose. Ld. Assessing Officer treated such transactions as non-genuine and disallowed the expenses u/s 37(1) of the Act. During the assessment proceedings

OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMTIED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI

In the result, appeal by the assessee is allowed

ITA 4044/MUM/2025[2021-22]Status: DisposedITAT Mumbai20 Feb 2026AY 2021-22

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR

Section 1

business. The said expenses mainly consisted of salary to its employees, professional fees and certain other expenses. These transactions were incurred wholly and exclusively for business purpose. Ld. Assessing Officer treated such transactions as non-genuine and disallowed the expenses u/s 37(1) of the Act. During the assessment proceedings

OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMTIED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI

In the result, appeal by the assessee is allowed

ITA 4043/MUM/2025[2019-20]Status: DisposedITAT Mumbai20 Feb 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR

Section 1

business. The said expenses mainly consisted of salary to its employees, professional fees and certain other expenses. These transactions were incurred wholly and exclusively for business purpose. Ld. Assessing Officer treated such transactions as non-genuine and disallowed the expenses u/s 37(1) of the Act. During the assessment proceedings

ACIT CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 3998/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR

Section 1

business. The said expenses mainly consisted of salary to its employees, professional fees and certain other expenses. These transactions were incurred wholly and exclusively for business purpose. Ld. Assessing Officer treated such transactions as non-genuine and disallowed the expenses u/s 37(1) of the Act. During the assessment proceedings

ACIT, CC-6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 3995/MUM/2025[2011-12]Status: DisposedITAT Mumbai20 Feb 2026AY 2011-12

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR

Section 1

business. The said expenses mainly consisted of salary to its employees, professional fees and certain other expenses. These transactions were incurred wholly and exclusively for business purpose. Ld. Assessing Officer treated such transactions as non-genuine and disallowed the expenses u/s 37(1) of the Act. During the assessment proceedings

AGNELO GUSTAVO EUGENIO RODRIGUES,MUMBAI vs. DY COMMISSIONER OF INCOME TAX CIRCLE 24 1 MUMBAI , MUMBAI

ITA 5079/MUM/2025[2007-08]Status: DisposedITAT Mumbai19 Feb 2026AY 2007-08

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Ajay Singh & Shri Akshay Pawar, ARsFor Respondent: Shri Surendra Mohan (Sr. DR)

IN THE INCOME-TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER

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

without pointing out any specific defects or discrepancies in the expenses claimed. The appellant submitted that all expenses were wholly and exclusively for business purposes and were supported by bills and vouchers. I agree with the appellant's submissions. The Id. AO's disallowance was arbitrary and without basis

JASIBAI DAYARAM AMLANI,AMRAVATI vs. DCIT AMRAVATI CIRCLE, AMRAVATI

In the result, appeal of the Assessee is partly allowed

ITA 749/NAG/2025[2014-15]Status: DisposedITAT Nagpur12 Feb 2026AY 2014-15

Bench: Dr. Manish Borad

For Appellant: Shri Rajesh Loya, CAFor Respondent: Shri Surjit Kumar Saha, Sr.DR

Section 143(2)Section 143(3)Section 144(3)Section 234ASection 250Section 40A(2)(b)

Shri Naresh Amlani by holding the same to be bogus. On the facts and circumstances of the case, the salary paid was wholly and exclusively for business purpose and was reasonable. The learned authorities were unjustified in holding otherwise. (4) That the learned CIT(A) erred

NATIONAL INSURANCE COMPANY LIMITED,NEW TOWN vs. DCIT, CIRCLE 5(1),, KOLKATA

In the result, the appeal filed by the assessee in ITA No

ITA 2806/KOL/2025[2023-2024]Status: DisposedITAT Kolkata12 Feb 2026AY 2023-2024

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 250Section 270ASection 37(1)Section 40C

which disallows expenses incurred for an unlawful purpose or in violation of law, even where otherwise incurred "wholly and exclusively for business. The restriction on management expenses is mandatory. The IRDA regulations do not merely allocate expense between shareholder and policyholder accounts but create a hard limit on the deductibility ... Section 37(1) which disallowed expenses incurred for an unlawful purpose or in violation of law even where otherwise incurred “wholly and exclusively for business”. According to the Ld. CIT(Appeals), NaFAC the limit prescribed by the IRDA in charging the expenses of Management to Revenue Account was allegedly