“wholly and exclusively for business”

Business ExpensesSection 37Section 37265 judgments

The decision most relied on for wholly and exclusively for business is Hero Cycles Pvt. Ltd. v. CIT (379 ITR 347), cited in 361 judgments on BharatTax.

Leading authorities on wholly and exclusively for business

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.

Indian Molasses Co. Pvt. Ltd. v. CIT

37 ITR 66 · 1959 · Supreme Court

206

citing judgments

Expenditure is defined as money paid out or away, which is gone irretrievably. To be deductible under Section 37(1), expenditure must be wholly and exclusively for business, not capital or personal, and not fall under specific provisions of Sections 30 to 36, often justifiable on grounds of commercial expediency.

CIT v. Dhanrajgirji Raja Narasingirji

91 ITR 544 · 1973 · Supreme Court

154

citing judgments

The revenue cannot question the commercial expediency or wisdom of an expenditure incurred by a businessman, as the businessman is the best judge of their own business interests. The department's role is limited to verifying if the expenditure was genuinely incurred and was wholly and exclusively for business purposes.

Sree Meenakshi Mills Ltd. v. Commissioner of Income Tax

31 ITR 28 · 1957 · Supreme Court

137

citing judgments

Expenditure incurred for commercial expediency, even without a direct or immediate benefit but indirectly facilitating business, is deductible as laid out wholly and exclusively for trade. The scope of reference jurisdiction under Section 66 is limited to questions of law, allowing challenges to Tribunal findings of fact only if they are perverse, unreasonable, or lack evidence.

Prakash Cotton Mills Pvt. Ltd. v. CIT

201 ITR 684 · 1993 · Supreme Court

133

citing judgments

Compensatory interest or damages paid for a breach of contract, arising in the normal course of business, are allowable as a deduction under section 37(1) as wholly and exclusively incurred for business purposes. This principle extends to indirect taxes paid in the course of business, which are admissible as business expenditure.

CIT v. Nestle India Ltd.

14 Taxmann 99 · 1983 · High Court

125

citing judgments

Club entrance fees, if incurred wholly and exclusively for business purposes, are allowable as revenue expenditure under Section 37(1). Furthermore, an order holding a deductor liable for TDS defaults under Section 201 must be preceded by an inquiry into the deductee's actual tax payment.

Lachminarayan Madan Lal v. CIT

86 ITR 439 · 1972 · Supreme Court

citing judgments

Even with an existing agreement, the deductibility of an amount claimed as an expenditure, such as commission, must be decided based on the specific facts and circumstances of each case, to ascertain if it was laid out wholly and exclusively for business purposes.

Haji Aziz & Abdul Shakoor Bros. v. CIT

41 ITR 350 · 1961 · Supreme Court

citing judgments

Penalties paid for a breach of law or contravention of statutory provisions are not allowable deductions as business expenditure because they cannot be considered wholly and exclusively laid out for the purpose of the business. This principle is now enshrined in Explanation 1 to Section 37(1) of the Income-tax Act, 1961.

Judgments citing wholly and exclusively for business

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 2804/KOL/2025[2018-2019]Status: DisposedITAT Kolkata12 Feb 2026AY 2018-2019

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

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 2803/KOL/2025[2018-2019]Status: DisposedITAT Kolkata12 Feb 2026AY 2018-2019

Bench: Shri George Mathan & Shri Rakesh Mishra

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

DCIT Circle 2(3)(1), Mumbai vs. Ndx P2P Private Limited, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 6490/MUM/2025[2022-23]Status: DisposedITAT Mumbai10 Feb 2026AY 2022-23

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

Section 142(1)Section 143(2)Section 37(1)Section 41(1)Section 44A

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “B” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAHUL

Rohan Landscape Private Limited, Mumbai vs. The Principle Commissioner of Income Tax, Mumbai

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

ITA 3635/MUM/2025[2020-21]Status: DisposedITAT Mumbai10 Feb 2026AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 139(1)Section 142(1)Section 143(2)Section 263Section 3

accepted accounting principles. On other expenses and business expenditure, the assessee reiterated that these were revenue in nature and incurred wholly and exclusively for business purposes. On depreciation, the assessee reiterated that assets had been put to use and depreciation was claimed strictly in accordance with law. 19. With regard

Karan Israni, New Delhi vs. DCIT, Central Circle-30, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 1627/DEL/2025[2019-20]Status: DisposedITAT Delhi04 Feb 2026AY 2019-20

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Muneesh Rajani, Sr. DR

Section 132Section 142(1)Section 153C

restrict the disallowance to the extent of 25% of such purchases. Under Section 37, the appellant must demonstrate that expenses were incurred wholly and exclusively for business purposes. In the absence of delivery proof, the appellant failed to discharge this burden. In view of above discussion, the addition

Deputy Commisioner of Income Tax Circle 3(1)(1) Ahmedabad, Ahmebabad vs. Techno Industries, Ahmedabad

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

ITA 660/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad03 Feb 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyaltechno Industries, Deputy Commissioner Of Vs. Plot No. 613, Phase Iv, Income-Tax, Gidc, Vatva, Circle 3(1)(1), Ahmedabad-382 245 Ahmedabad [Pan : Aacft 1503 D] (Appellant) .. (Respondent) Assessee By : Shri Bandish Soparkar, Ar Respondent By: Shri Abhijit, Sr Dr Date Of Hearing 27.11.2025 Date Of Pronouncement 03.02.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:- This Appeal Has Been Filed By The Revenue Against The Order Dated 22.01.2025 Passed By The Ld. Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi (“Ld. Cit(A)” For Short), Under Section 250 Of The Income-Tax Act, 1961 (“The Act” For Short), Relating To The Assessment Year 2017- 18. 2. The Revenue Has Raised Following Grounds Of Appeal :- “(1) The Ld. Cit(A) Has Erred In Law & On Facts In Deleting The Addition Of Rs 1,03,00,000/- Made By Ao On Account Of Unsecured Loan Received From Various Lenders U/S. 68 Of It Act, Despite The Fact That The Assessee Had Not Corroborative Evidences Identity Genuineness/Creditworthiness Of The Lenders During Assessment Establish The Proceedings. (2) The Ld. Cit(A) Has Erred In Law & On Facts In Admitting The Additional Evidences During Appellate Proceedings, Without Giving The Opportunity To The Ao As Required By Rule 46A.. (3) The Ld. Cita) Has Erred In Law & On Facts In Deleting The Addition Of Rs.1,66,037/- Made By Ao On Account Of Disallowance Of Interest On Unsecured Loans Paid To Lenders, Despite The Fact That The Assessee Had Not Dcit Vs. Techno Industries Asst. Year : 2017-18 - 2–

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Abhijit, Sr DR

Section 143(3)Section 250Section 36(1)(va)Section 68

Interest 6. The Assessing Officer disallowed interest expenditure of Rs.1,66,037/- on the ground that borrowed funds were not used wholly and exclusively for business purposes. The Ld. CIT(A) deleted the disallowance holding that the Assessing Officer failed to establish any nexus between borrowed funds and non- business

Tbz Nirmal Zaveri Private Limited, Mumbai vs. Addl/JCIT (A) Bhubaneshwar, Mumbai

In the result, the appeal filed by the assesse bearing

ITA 6450/MUM/2025[2014-15]Status: DisposedITAT Mumbai22 Jan 2026AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Gunjan KakkadFor Respondent: Shri Hemanshu Joshi (SR DR)

Section 115JSection 143(3)Section 250

expenses.” He further submitted that the payments were made to related parties without adequate justification to establish that the expenditure was incurred wholly and exclusively for business purposes. He accordingly relied upon the orders of the revenue authorities. 6. We have heard the rival submissions and perused the material available

Misrilall Jain & Sons, Singhbhum West vs. ACIT, Central Circle-1, Ranchi

In the result the appeal filed by the assessee is allowed

ITA 468/RAN/2024[2017-18]Status: DisposedITAT Ranchi21 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.468/Ran/2024 Assessment Year: 2017-18 Misrilall Jain & Sons….…………….…….…............................……….……Appellant M. D. House, Chaibasa Singhbhum West, Jharkhand – 833201. [Pan: Aabfm2851Q] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 21, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 30.07.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

Section 143(3)Section 148Section 148ASection 250

made by the partners does not disentitle the assessee from claiming the expenses, when it is established that the expenses were incurred wholly and exclusively for business purposes and were reimbursed by the firm. In view of the above facts, we find that the disallowance

Deputy Commissioner of Income Tax, Circle-1(1), Chandigarh vs. Frontier Agrotech Private Limited, Chandigarh

ITA 388/CHANDI/2025[2022-23]Status: DisposedITAT Chandigarh14 Jan 2026AY 2022-23

Bench: The Appeal Is Heard Or Is Disposed Off.

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 143(3)Section 144B

credit, or accounting treatment of corresponding purchase 3 returns. Holding that the expenditure was either unverifiable or unsubstantiated, and therefore not incurred wholly and exclusively for business purposes, the AO disallowed the disputed amounts, increased the income returned, and completed assessment under section 143(3) read with section 144B

Aqua World Exports Pvt. Ltd., Chennai vs. DCIT, Corporate Circle-1(1), Chennai

In the result, the appeal of the Assessee is allowed

ITA 2004/CHNY/2025[2017-18]Status: DisposedITAT Chennai05 Jan 2026AY 2017-18

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

For Appellant: Ms. S. Vidya, C.AFor Respondent: Ms. R. Anitha, Addl. C.I.T

Section 142(1)Section 143(3)Section 40Section 40A(3)

business expediency or Rule 6DD, this factual backdrop lends support to the assessee’s claim that the payments were genuine and incurred wholly and exclusively for business purposes. :-7-: ITA. No:2004/Chny/2025 16. In view of the above discussion and in the present facts and circumstances of the case

Integrated Service Point Ltd., Chennai vs. ACIT, CC-2(4), Chennai

ITA 1883/CHNY/2025[2022-23]Status: DisposedITAT Chennai30 Dec 2025AY 2022-23

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Pvt. Ltd.,) Vs. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing घोषण की तारीख / Date Of Pronouncement : 13.10.2025 : 30.12.2025 :- 2 -:

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT

Section 132Section 132(4)Section 134(4)Section 250

cash outflows. The assessee emphasized that although such entries were not reflected in the regular books of account, the expenditures were incurred wholly and exclusively for business purposes and were duly evidenced by corresponding debit entries in the same seized records. It was further contended that transportation rates were paid ... without considering the additional income admitted in the revised computation. The assessee strongly contended that the expenses were incurred wholly and exclusively for business purposes and that the AO's reliance solely on the statement of Shri Stanley Babu-which was subsequently retracted—was inappropriate and unsupported by corroborative evidence

Integrated Service Point Ltd., Chennai vs. ACIT, Central Circle-2(4), Chennai

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

ITA 1882/CHNY/2025[2019-20]Status: DisposedITAT Chennai30 Dec 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT

Section 132Section 132(4)Section 134(4)Section 250

cash outflows. The assessee emphasized that although such entries were not reflected in the regular books of account, the expenditures were incurred wholly and exclusively for business purposes and were duly evidenced by corresponding debit entries in the same seized records. It was further contended that transportation rates were paid ... without considering the additional income admitted in the revised computation. The assessee strongly contended that the expenses were incurred wholly and exclusively for business purposes and that the AO’s reliance solely on the statement of Shri Stanley Babu—which was subsequently retracted—was inappropriate and unsupported by corroborative evidence

Integrated Service Point Ltd., Chennai vs. ACIT, Central Circle-2(4), Chennai

ITA 1881/CHNY/2025[2016-17]Status: DisposedITAT Chennai30 Dec 2025AY 2016-17

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Income Tax, Pvt. Ltd.,) The Dy./Asst. Commissioner Of Central Circle-2(4), 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Chennai. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 13.10.2025 घोषण की तारीख / Date Of Pronouncement : 30.12.2025 :- 2 -:

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT

Section 132Section 132(4)Section 134(4)Section 250

ACIT, Chennai vs. Integrated Service Point Limited, Anna Nagar

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

ITA 1879/CHNY/2025[2022-23]Status: DisposedITAT Chennai30 Dec 2025AY 2022-23

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT

Section 132Section 132(4)Section 134(4)Section 250

cash outflows. The assessee emphasized that although such entries were not reflected in the regular books of account, the expenditures were incurred wholly and exclusively for business purposes and were duly evidenced by corresponding debit entries in the same seized records. It was further contended that transportation rates were paid ... without considering the additional income admitted in the revised computation. The assessee strongly contended that the expenses were incurred wholly and exclusively for business purposes and that the AO’s reliance solely on the statement of Shri Stanley Babu—which was subsequently retracted—was inappropriate and unsupported by corroborative evidence

ACIT, Nungambakkam vs. Integrated Service Point Limited, Anna Nagar

ITA 1876/CHNY/2025[2019-20]Status: DisposedITAT Chennai30 Dec 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 13.10.2025 घोषण की तारीख / Date Of Pronouncement : 30.12.2025 :- 2 -:

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT

Section 132Section 132(4)Section 134(4)Section 250

ACIT, Nunagambakkam vs. Integrated Service Point Limited, Anna Nagar

ITA 1874/CHNY/2025[2016]Status: DisposedITAT Chennai30 Dec 2025

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Income Tax, Pvt. Ltd.,) The Dy./Asst. Commissioner Of Central Circle-2(4), 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P Chennai. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Integrated Service Point Ltd., Income Tax, Central Circle-2(4), Chennai. (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख / Date Of Pronouncement 13.10.2025 30.12.2025 - : 2 -:

For Appellant: Mr. Y. Sridhar, FCA

Section 132Section 132(4)Section 134(4)Section 250

cash outflows. The assessee emphasized that although such entries were not reflected in the regular books of account, the expenditures were incurred wholly and exclusively for business purposes and were duly evidenced by corresponding debit entries in the same seized records. It was further contended that transportation rates were paid ... without considering the additional income admitted in the revised computation. The assessee strongly contended that the expenses were incurred wholly and exclusively for business purposes and that the AO's reliance solely on the statement of Shri Stanley Babu—which was subsequently retracted—was inappropriate and unsupported by corroborative evidence

U.P.Cooperative Federationltd, Lucknow vs. ITO-2(3), Lucknow

In the result, the appeal of the assessee is dismissed

ITA 260/LKW/2023[2003-14]Status: DisposedITAT Lucknow19 Dec 2025AY 2003-14

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraआयकर अपील सं/ Ita No.260/Lkw/2023 ननिाारण वर्ा/ Assessment Year: 2003-04 U.P. Cooperative Federation V. Income Tax Officer-2(3) Ltd Pratyaksh Kar Bhawan, Pcf Building, 32, Station Road, 57, Ram Tirath Marg, Lucknow-226004. Hazratganj, Lucknow- 226001. Pan:Aaaau0373P अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Shri D. D. Chopra, Advocate प्रत्यर्थी कक और से /Respondent By: Shri Neeraj Kumar, Cit(Dr) सुनवाई कक तारीख / Date Of Hearing: 22 09 2025 घोर्णा कक तारीख/ Date Of 19 12 2025 Pronouncement: आदेश / O R D E R

For Appellant: Shri D. D. Chopra, AdvocateFor Respondent: Shri Neeraj Kumar, CIT(DR)

Section 142Section 142(2)(a)Section 153(2)(a)Section 271Section 80PSection 80P(2)

Tribunal further observed that no conclusive finding could be recorded as to whether the expenses were incurred wholly and exclusively for business purposes unless the relevant material was examined by the Assessing Officer. Accordingly, the Tribunal restored the matter back to the file of the Assessing Officer with a direction

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

Sassoon J. David (118 ITR 261) has settled that losses arising in the ordinary course of business and expenses incurred wholly and exclusively for business . ITA No.330,331,496,543 &544/Bang/2024 S.A No.25/Bang/2025 Page 24 of 46 purposes are allowable, even if they do not result in immediate profit ... neither capital nor personal in nature, has been incurred in the relevant year, and is wholly and exclusively for business purposes. By incentivizing employees, the scheme directly contributed to business efficiency and growth. The assessee emphasized that the ESOP expenditure met all statutory conditions for allowability and should

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

Sassoon J. David (118 ITR 261) has settled that losses arising in the ordinary course of business and expenses incurred wholly and exclusively for business ITA No.330,331,496,543 &544/Bang/2024 S.A No.25/Bang/2025 Page 24 of 46 purposes are allowable, even if they do not result in immediate profit ... neither capital nor personal in nature, has been incurred in the relevant year, and is wholly and exclusively for business purposes. By incentivizing employees, the scheme directly contributed to business efficiency and growth. The assessee emphasized that the ESOP expenditure met all statutory conditions for allowability and should

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