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“capital expenditure”

Business ExpensesSection 37Section 373,515 judgments

The decision most relied on for capital expenditure is Empire Jute Co. Ltd. v. CIT (124 ITR 1), cited in 622 judgments on BharatTax.

Leading authorities on capital expenditure

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.

Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT
227 ITR 172 · 1997 · Supreme Court
621
citing judgments

Interest income earned on deposits, particularly before the commencement of business operations or as a requirement for business licensing, is taxable as "income from other sources" under Section 56, and cannot be treated as business income or set off against interest on borrowed funds.

Madras Industrial Investment Corporation Ltd. v. CIT
225 ITR 802 · 1997 · Supreme Court
568
citing judgments

Expenditure that provides an enduring benefit should be amortized over its useful life, not allowed as a deduction in a single year, to prevent a distorted picture of profits. Specifically, premium paid on debentures for their issue should be amortized on a straight-line method over the life of the debentures.

South Indian Bank Ltd. v. CIT
438 ITR 1 · 2021 · Supreme Court
508
citing judgments

The mixed fund theory is affirmed, holding that no disallowance of interest expenditure under Section 14A can be made if the assessee possesses sufficient non-interest bearing funds, such as capital and reserves, to cover investments made in tax-free securities.

CIT v. Institute of Banking Personnel Selection
264 ITR 110 · 2003 · High Court
398
citing judgments

Depreciation is allowable on assets for which the cost has been fully allowed as an application of income under Section 11 in previous years, when computing the income of a charitable trust. Charitable trusts are also entitled to carry forward their deficit.

Taparia Tools Ltd. v. JCIT
372 ITR 605 · 2015 · Supreme Court
343
citing judgments

An expenditure does not automatically become capital in nature merely because it results in some enduring benefit for the assessee; it can be treated as revenue expenditure if incurred for genuine business purposes.

Biocon Ltd. v. DCIT
35 Taxmann.com 335 · 2013 · ITAT
322
citing judgments

The discount arising from the grant of Employee Stock Option Plans (ESOPs) is an allowable business expenditure under Section 37(1) of the Income-tax Act, 1961, as it is an ascertained liability, not a contingent one, and constitutes a revenue expense rather than a capital expense.

Alembic Chemical Works Co. Ltd. v. CIT
177 ITR 377 · 1989 · Supreme Court
275
citing judgments

Expenditure that provides a commercial advantage of an enduring nature may still be classified as revenue expenditure if its purpose is to facilitate existing trading operations, improve business efficiency, or upgrade existing products, depending on the specific context and objective.

Judgments citing capital expenditure

Sun Pharma Laboratories Ltd., Mumbai vs. The Dy. Commissioner of Income Tax, Circle-2(1)(1), Baroda

In the result, the Department’s appeal is partly allowed

ITA 712/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad09 Oct 2024AY 2015-16

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 36(1)(va)Section 37(1)Section 80Section 80I

Arrangement. The Ld AO at para 19 of the assessment order has observed that RoC filing fees paid for increase in share capital is capital expenditure in view of decisions of Brooke Bond India Ltd Vs CIT [225 ITR 798] and Punjab State Industrial Development Corporation ... held that the said software expenses gives benefit which would be available for more than one year i.e. enduring in nature and held as capital expenditure. The Ld CIT[A] held that software I.T.A Nos.712 & 741 /Ahd/2019 A.Y. 2015-16 38 Sun Pharma Labs. Ltd. vs. DCIT upgradation expenses

Tmilnad Mercantile Bank Limited, Tuticorin vs. ACIT, Circle-1, Tirunelveli

In the result, appeal filed by the assessee stands allowed

ITA 788/CHNY/2024[2010-11]Status: DisposedITAT Chennai09 Oct 2024AY 2010-11

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.788/Chny/2024 िनधा"रण वष"/Assessment Year: 2010-11 V. M/S. Tamilnad Mercantile Bank Ltd., The Acit, 57 V E Road, Circle-1, Tuticorin Central Bus Stand, Tirunelveli. S.O. Thoothukudi, Tuticorin-628 002. [Pan: Aaact 5558 K] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(1)Section 143(3)Section 147Section 148Section 36(1)Section 36(1)(viia)

under Section 143(3) of the Act and the original assessment was completed on 28.07.2004. Its claim under Section 37(1) for allowance of capital expenditure by way of royalty to the tune of `39,57,72,326/- in lieu of technical knowledge and depreciation of fixed assets was allowed

Ppap Automotive Limited, New Delhi vs. The Deputy Commissioner of Income Tax, Circle - 19(1), New Delhi

In the result appeal of the assessee is allowed

ITA 47/DEL/2024[2017-18]Status: DisposedITAT Delhi08 Oct 2024AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumarppap Automotive Limited, Vs. Dcit, 54 Okhla Industrial Estate, Circle-19(1), New Delhi Phase Iii, South East Delhi, New Delhi-110020 (Appellant) (Respondent) Pan:Aaacp5144P

For Appellant: Shri Vikash Singh, CAFor Respondent: Shri Kanv Bali, Sr. DR
Section 143(3)

being 25 percent of the expenditure incurred towards royalty made by the Ld. AO by holding the same as capital expenditure. 3. That the Ld. CIT(A) has erred in confirming the aforesaid disallowance by ignoring the explanation and evidences brought on record by the appellant PPAP Automotive Limited company

Asst. Commissioner of Income-Tax 6(1)(2), Mumbai vs. Franklin Templeton Asset Management (India) Pvt. Ltd., Mumbai

In the result appeal filed by the learned AO is dismissed

ITA 2727/MUM/2024[2015-16]Status: DisposedITAT Mumbai07 Oct 2024AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm A.Y.2015-16 Asst Commissioner Of Income Franklin Templeton Asset Tax, Management (I) Pvt. Ltd., Circle 6(1)(2), One International Centre, Tower 2, 12Th 13Th Floor, Mumbai Vs . Senapati Bapat Marg, Elphinstone (W), Delisle Road, S.O., Mumbai 400013 (Appellant) (Respondent) Pan Aaact 1609B Assessee By Shri Anish Thacker & Lekh Mehta Revenue By Shri Anil Sant- Addl., Cit(Dr), 22Nd July, 2024 Date Of Hearing 07Th October, 2024 Date Of Pronouncement

Section 143Section 144CSection 37

whereas the learned Assessing Officer held that same is a one- time expense generating advantage for future years and therefore it is a capital expenditure which was allowed by the learned CIT – A. 3. The brief fact of the case shows that assessee is an asset management company of Franklin ... Ground No. 1 is dismissed. 8. Ground No. 2 is with respect to the issue whether the launch expenses incurred by the assessee are capital expenditure or revenue expenditure. The claim of the assessee is those expenses are revenue in nature, the claim of the learned AO is that those

Shree Krishna Gaushala, Ramgarh Shekhawati Sikar vs. Income Tax Officer (Exemption), Ward-II Jaipur

In the result, the appeal of the assessee is partly allowed for statistical purposes with no orders as to cost

ITA 399/JPR/2024[2012-2013]Status: DisposedITAT Jaipur04 Oct 2024AY 2012-2013

Bench: Hon’ble SHRI SANDEEP GOSAIN, JUDICIAL MEMBER vk;dj vihy la-@ITA No. 399/JP/2024 fu/kZkj.k o"kZ@Assessment Year : 2012-13 Shree Krishna Gaushala Ramgarh Shekhawati Sikar cuke Vs. The ITO (Exemption) Ward -II Sikar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAATS 5144H vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@Assessee by : Shri Saurv Harsh, Advocate jktLo dh vksj ls@Revenue by: Shri Gautam Singh Choudhary,JCIT-DR lquokbZ dh rkjh[k@Date of Hearing : 25/09/2024 mn?kks"k.kk

For Appellant: Shri Saurv Harsh, AdvocateFor Respondent: Shri Gautam Singh Choudhary,JCIT-DR
Section 143(3)

Total receipts: 95,59,674/- Payments: 94,75,656/- Less closing balance: - 11,36,978/- Less fixed deposits: - 14,14,420/- Less capital expenditure: - 17,96,198/- Add expenses to well a/c to the extent not included: 2,02,304/- Total expenses: 53,30,364/- Net Profit

Bhartiya Samruddhi Investments and Consulting Services Limited, Delhi vs. ACIT, Circle 4(2), Delhi

In the result, the Assessee’s appeal is allowed

ITA 1637/DEL/2023[2012-13]Status: DisposedITAT Delhi04 Oct 2024AY 2012-13

Bench: Shri Shamim Yahya & Ms. Madhumita Roya.Yr. : 2012-13 Bhartiya Samruddhi Vs. Acit, Circle 4(2), Investments & Consulting New Delhi Services Limited, F-5, Ground Floor, Greater Kailash, Kailash Colony, Part-I, New Delhi – 110 048 (Pan: Aaacb5336R) (Appellant) (Respondent)

For Appellant: Shri Arvind Kumar, AdvFor Respondent: Shri Raghunath, Sr. DR
Section 142(1)Section 143(3)Section 147Section 148Section 151Section 37

Section 37 of the I.T. Act. ii) Section 37 of the I.T. Act provides that any expenditure, not being in the nature of capital expenditure, laid out wholly or exclusively for the purpose of business is allowable as deduction in computing income chargeable under the had profits and gains ... business or profession. Thus, all expenditure, other than capital expenditure which is incurred in relation to the business is allowable. iii) In view of the above you are required to show cause as to why the above claim of deduction on account of sundry advances / assets written off amounting

Mcnally Sayaji Engineering Limited, Kolkata vs. DCIT, Circle - 1(1), Kolkata

In the result, both the appeals are dismissed

ITA 899/KOL/2018[2009-10]Status: DisposedITAT Kolkata03 Oct 2024AY 2009-10

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2009-10 & Assessment Year: 2013-14 Mcnally Sayaji Engineering Deputy Commissioner Of Limited, Income Tax, Circle 1(1), Ecospace, Campus 2B, 11F/12 Aayakar Bhavan, P-7, (Old Plot No. Aa Ii/Blk 3), Chowringhee Square, Vs New Town, Rajarhat, Kolkata - 700069 North 24 Paragans, Kolkata - 7000156 (Pan: Aaccs5491A) (Appellant) (Respondent) Present For: Appellant By : Shri Abhishek Sureka, Ar Respondent By : Shri Rakesh Kumar Das, Cit, Dr Shri Vineet Kumar, Addl. Cit, Sr. Dr Date Of Hearing : 08.07.2024 Date Of Pronouncement : 03.10.2024 O R D E R Per Rakesh Mishra: These Two Appeals Filed By The Assessee Are Against The Two Separate Orders Of The Ld. Commissioner Of Income Tax, Kolkata-I, Kolkata (Hereinafter Referred To As “The Ld. Cit”) Passed U/S 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) For Ays 2009-10 & 2013- 14, Dated 28.02.2018 & 13.03.2018 Respectively. Both The Appeals Were Heard Together & Are Being Disposed Of Vide This Common Order For The Sake Of Brevity & Convenience. Mcnally Sayaji Engineering Limited.: Ays: 2009-10 & 2013-14 2. The Grounds Of Appeal Raised By The Assessee Are Reproduced As Under:

For Appellant: Shri Abhishek Sureka, ARFor Respondent: Shri Rakesh Kumar Das, CIT, DR
Section 234CSection 250Section 37Section 40

consider and appreciate that the advisory fee of Rs. 2,00,000/- paid by the appellant was a revenue expenditure and not a capital expenditure 6) For that without prejudice to the above, the Ld CIT(A) has failed to consider and appreciate that the advisory fee had been incurred

Mcnally Sayaji Engineering Limited, Kolkata vs. DCIT, Circle - 1(1), Kolkata

In the result, both the appeals are dismissed

ITA 1145/KOL/2018[2013-14]Status: DisposedITAT Kolkata03 Oct 2024AY 2013-14

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2009-10 & Assessment Year: 2013-14 Mcnally Sayaji Engineering Deputy Commissioner Of Limited, Income Tax, Circle 1(1), Ecospace, Campus 2B, 11F/12 Aayakar Bhavan, P-7, (Old Plot No. Aa Ii/Blk 3), Chowringhee Square, Vs New Town, Rajarhat, Kolkata - 700069 North 24 Paragans, Kolkata - 7000156 (Pan: Aaccs5491A) (Appellant) (Respondent) Present For: Appellant By : Shri Abhishek Sureka, Ar Respondent By : Shri Rakesh Kumar Das, Cit, Dr Shri Vineet Kumar, Addl. Cit, Sr. Dr Date Of Hearing : 08.07.2024 Date Of Pronouncement : 03.10.2024 O R D E R Per Rakesh Mishra: These Two Appeals Filed By The Assessee Are Against The Two Separate Orders Of The Ld. Commissioner Of Income Tax, Kolkata-I, Kolkata (Hereinafter Referred To As “The Ld. Cit”) Passed U/S 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) For Ays 2009-10 & 2013- 14, Dated 28.02.2018 & 13.03.2018 Respectively. Both The Appeals Were Heard Together & Are Being Disposed Of Vide This Common Order For The Sake Of Brevity & Convenience. Mcnally Sayaji Engineering Limited.: Ays: 2009-10 & 2013-14 2. The Grounds Of Appeal Raised By The Assessee Are Reproduced As Under:

For Appellant: Shri Abhishek Sureka, ARFor Respondent: Shri Rakesh Kumar Das, CIT, DR
Section 234CSection 250Section 37Section 40

consider and appreciate that the advisory fee of Rs. 2,00,000/- paid by the appellant was a revenue expenditure and not a capital expenditure 6) For that without prejudice to the above, the Ld CIT(A) has failed to consider and appreciate that the advisory fee had been incurred

Tmf Holdings Ltd, Mumbai vs. ACIT Circle 1(3)(2), Mumbai

In the result, the grounds raised by the assessee are allowed

ITA 2031/MUM/2024[2015-16]Status: DisposedITAT Mumbai03 Oct 2024AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

Section 143(3)Section 234DSection 36(1)Section 36(1)(iii)Section 43B

First Appellate authority is that assessee is being business of vehicle financing and it has to meet its day-to-day capital expenditure for which it requires substantial funds. The assessee has raised funds by way of issue of perpetual debentures and objects of the issues have been stated ... Holdings Ltd. debenture disclosure document that it has to be used for various financing activities; Repay existing loans; Business expenditure including capital expenditure and working capital requirements, etc. Here in this case, it is a fact that perpetual debentures carry a 'call-option' which may be exercised by the assessee

Income Tax Officer, Mumbai Ayakar Bhawan Churchgate vs. Varsha Corporation Limited, Malad (West)

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

ITA 348/MUM/2024[2017-18]Status: DisposedITAT Mumbai01 Oct 2024AY 2017-18

Bench: Ms. Kavitha Rajagopal & Shri Gagan Goyalito, R. No. 227, Aayakar Bhavan, M. K. Road, Mumbai Maharashtra - 400 020. ..... Appellant Vs. M/S. Varsha Corporation Ltd. 13, Adarsh Society, Varsha Ramachandra Lane Extn. Malad (West), Mumbai- 400 064. Pan No.Aabcv2293E ..... Respondent

For Appellant: Ms. Rajeshwari Menon, Ld. DRFor Respondent: Shri Mahesh Rajora, Ld.AR
Section 133(6)Section 143(1)Section 143(3)Section 250

General. 37. (1) Any expenditure (not being expenditure of the nature described in sections 30 to 36 and not being in the nature of capital expenditure or personal expenses of the assessee), laid out or expended wholly and exclusively for the purposes of the business or profession shall be allowed

Assistant Commissioner of Income Tax, Kolhpaur vs. Rbl Bank Ltd, Kolhapur

In the result, the appeal of the Revenue is dismissed

ITA 657/PUN/2024[2014-15]Status: DisposedITAT Pune30 Sept 2024AY 2014-15

Bench: SATBEER SINGH GODARA, JUDICIAL MEMBER, AND DR.DIPAK P. RIPOTE (Accountant Member)

Section 139(1)Section 143(2)Section 250Section 271Section 271(1)(c)

revenue expenditure but capital expense. There is a fine distinction as to when an expenditure can be treated as a revenue or a capital expenditure. Therefore, merely for the reason that the assessee has claimed the expenditure to be revenue will not render the assessee liable to penalty proceedings ... business portfolio of RBS India and professional fees paid for the same as Revenue Expenditure. The AO in the Assessment Order held it as Capital Expenditure for acquiring Intangible Asset and allowed Depreciation. Second Addition is on account of Bad Debts claimed u/sec.36(1)(vii) of Rs.65,97,164/-. Third

Geevarghese Yohannan Charitable Trust, Trivandrum vs. CIT Exemptions, Kochi

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

ITA 295/COCH/2023[2018-19]Status: DisposedITAT Cochin30 Sept 2024AY 2018-19

Bench: Shri Waseem Ahmed, Accountantmemberand Shri Soundararajan K., Judicialmember Geevarghese Yohannan Charitable Cit(Exemption) 2Nd Floor, San Juan Towers Trust 12-H Capitol Centre, Statue Vs. Old Rly. Station Road Thiruvananthapuram 605001 Kochi 682018 [Pan: Aabtg3042K] (Appellant) (Respondent)

For Appellant: Shri Surendranath Rao, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115BSection 143(3)Section 263Section 69C

Geevarghese Yohannan Charitable Trust of the Acthas made addition to the tune of Rs. 8,95,62,201/-, representing the capital expenditure shown as application of income,to the total income of the assessee treating the same as bogus in nature. According to the CIT (Exemptions) such addition should have ... before us filed a paper book running from pages 1 to 117 and contended that the addition made by the AO qua the capital expenditure claimed by the assessee as application of income of Rs. 8,95,62,201/- cannot be made subject to tax at special rate u/s 115BBE

DCIT 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

Accordingly, (a) all the grounds raised by the Revenue are dismissed, (b) Cross Objection 1 (1

ITA 3372/MUM/2023[2015-16]Status: DisposedITAT Mumbai30 Sept 2024AY 2015-16

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Yogesh Thar a/w ChaitanyaFor Respondent: Shri Biswanath Das
Section 143(3)Section 14ASection 153

paid on securities classified under the category of ‘Held to maturity’ (HTM) on the alleged ground that the same is in the nature of capital expenditure without considering the fact that the securities purchased forms part of Bank’s stock-in- trade. 2.1.3. The Ld. Assessing Officer erred in making

DCIT CC- 1(3), Aaykar Bhavan vs. Montecarlo Limited, Sindhu Bhawan Road, Bodakdev

In the result, the appeal filed by the revenue in ITA

ITA 599/AHD/2023[2020-21]Status: DisposedITAT Ahmedabad27 Sept 2024AY 2020-21

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V Mahadeokar (Accountant Member)

Section 143(3)Section 80I

purpose of business is allowable expenditure if it does not fall within any exception provided therein. The expenditure incurred by Assessee is not capital expenditure or any prohibited expenditure hence such expenditure is required to be allowed in the year under consideration. 12.3 It is observed that as ICDS ... projects awarded by NHAI hence such expenditure is part of business operation of appellant and even cannot be treated as capital expenditure. 12.4 It is observed that Assessee Company is a limited company and rate of taxation for the current year and subsequent year is the same. When the Assessee

DCIT CC- 1(3), Aaykar Bhawan vs. Montecarlo Limited, Montecarlo House, Sindhu Bhawa

In the result, the appeal filed by the revenue in ITA

ITA 598/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 Sept 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V Mahadeokar (Accountant Member)

Section 143(3)Section 80I

purpose of business is allowable expenditure if it does not fall within any exception provided therein. The expenditure incurred by Assessee is not capital expenditure or any prohibited expenditure hence such expenditure is required to be allowed in the year under consideration. 12.3 It is observed that as ICDS ... projects awarded by NHAI hence such expenditure is part of business operation of appellant and even cannot be treated as capital expenditure. 12.4 It is observed that Assessee Company is a limited company and rate of taxation for the current year and subsequent year is the same. When the Assessee

DCIT, Central Circle- 1(3), Ahmedabad vs. M/S Lok Prakashan Ltd., Ahmedabad

The appeal of the Revenue is dismissed accordingly

ITA 480/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 Sept 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

For Appellant: Shri Vartik Choksi, ARFor Respondent: Shri Prathvi Raj Meena, CIT-DR
Section 143(3)Section 14ASection 250

business growth in the immediate term, suggesting they provided long-term benefits rather than immediate operational gains. The AO classified the expenses as capital expenditures, arguing that they created enduring benefits for the business. Past disallowances of similar expenses were cited to justify the AO’s stance that these expenses

DCIT, Central Circle - 1(3), Ahmedabad vs. M/S Lok Prakashan Ltd., Ahmedabad

The appeal of the Revenue is dismissed accordingly

ITA 479/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad27 Sept 2024AY 2017-18

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

For Appellant: Shri Vartik Choksi, ARFor Respondent: Shri Prathvi Raj Meena, CIT-DR
Section 143(3)Section 14ASection 250

business growth in the immediate term, suggesting they provided long-term benefits rather than immediate operational gains. The AO classified the expenses as capital expenditures, arguing that they created enduring benefits for the business. Past disallowances of similar expenses were cited to justify the AO’s stance that these expenses

Lok Prakashan Limited, Ahmedabad vs. ACIT, Central Circle-1(3), Ahmedabad

The appeal of the Revenue is dismissed accordingly

ITA 291/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 Sept 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

For Appellant: Shri Vartik Choksi, ARFor Respondent: Shri Prathvi Raj Meena, CIT-DR
Section 143(3)Section 14ASection 250

business growth in the immediate term, suggesting they provided long-term benefits rather than immediate operational gains. The AO classified the expenses as capital expenditures, arguing that they created enduring benefits for the business. Past disallowances of similar expenses were cited to justify the AO’s stance that these expenses

Lok Prakashan Limited, Ahmedabad vs. ACIT, Central Circle-1(3), Ahmedabad

The appeal of the Revenue is dismissed accordingly

ITA 290/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad27 Sept 2024AY 2017-18

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

For Appellant: Shri Vartik Choksi, ARFor Respondent: Shri Prathvi Raj Meena, CIT-DR
Section 143(3)Section 14ASection 250

business growth in the immediate term, suggesting they provided long-term benefits rather than immediate operational gains. The AO classified the expenses as capital expenditures, arguing that they created enduring benefits for the business. Past disallowances of similar expenses were cited to justify the AO’s stance that these expenses

Super Nova Plywoods, Perumbavoor vs. The ITO, Ward 3, Aluva

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

ITA 238/COCH/2023[2011-12]Status: DisposedITAT Cochin27 Sept 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Super Nova Plywoods Income Tax Officer Puliyampilly Road, Allapara Ward - 3, Aluva Vs. Kutipadam, Perumbavoor 683556 [Pan: Abhfs4930M] (Appellant) (Respondent)

For Appellant: ------- None ------For Respondent: Smt. Girly Albert, Sr. D.R

Super Nova Plywoods verified independently. Accordingly he disallowed 20% of these expenses. The appellant has mentioned that part of these expenses were capital expenditure. If the is submission of the appellant is considered then the entire expenditure would be disallowed as revenue expenditure. Further appellant has not submitted any documentary