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“revenue expenditure”

Business ExpensesSection 37Section 373,350 judgments

The decision most relied on for revenue expenditure is CIT v. Woodward Governor India Pvt. Ltd. (312 ITR 254), cited in 968 judgments on BharatTax.

Leading authorities on revenue expenditure

CIT v. Woodward Governor India Pvt. Ltd.
312 ITR 254 · 2009 · Supreme Court
968
citing judgments

Foreign exchange fluctuations, whether gains or losses, are inextricably linked to the underlying business transaction and must be accounted for under the mercantile system. The Supreme Court also affirmed the standard accounting principle of valuing stock at cost or net realisable value, whichever is lower.

CIT v. Excel Industries Ltd.
358 ITR 295 · 2013 · Supreme Court
935
citing judgments

When an income or expenditure is revenue neutral across different assessment years, where any benefit derived is offset by a corresponding liability or reversal, no additional tax liability arises, particularly concerning income recognition under the mercantile system of accounting.

Rotork Controls India Pvt. Ltd. v. CIT
314 ITR 62 · 2009 · Supreme Court
739
citing judgments

A provision for expenses, such as warranty, is a deductible liability for income tax purposes if it constitutes a present obligation arising from past events, and a reliable estimate of the amount of obligation is possible.

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.

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.

Umacharan Shaw & Bros. v. CIT
37 ITR 271 · 1959 · Supreme Court
567
citing judgments

An income tax assessment or addition cannot be sustained solely on the basis of suspicion, surmises, or conjectures, as strong suspicion does not amount to proof. The revenue authorities must rely on concrete evidence and material to frame an assessment.

Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT
374 ITR 118 · 2015 · High Court
499
citing judgments

The existence of an international transaction for Advertising and Marketing Promotion (AMP) expenditure requires the revenue to discharge the burden of proof. An explanation inserted under Section 92B does not automatically make AMP expenditure an international transaction.

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.

Judgments citing revenue expenditure

Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore vs. M/S Infosys Ltd, Bangalore

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

ITA 1557/BANG/2017[2007-08]Status: DisposedITAT Bangalore30 Nov 2022AY 2007-08

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

carpets and refurbishing of hotel rooms in tune with international standards without addition of extra floor space or extra room capacity was allowable as revenue expenditure. The Ld.AR thus submitted that in the present case also, the expenditure did not result in increase in the capacity or extra building space ... case of CIT vs. Oxford University Press reported in 108 ITR 166 has expounded that, the test for judging the nature of capital or revenue expenditure is to see whether as a result of expenditure what is being done is to preserve and maintain an already existing asset or whether

M/S Infosys Ltd, Bangalore vs. The Assistant Commissioner of Income Tax Circle-3(1)(1), Bangalore

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

ITA 1532/BANG/2017[2009-10]Status: DisposedITAT Bangalore30 Nov 2022AY 2009-10

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

carpets and refurbishing of hotel rooms in tune with international standards without addition of extra floor space or extra room capacity was allowable as revenue expenditure. The Ld.AR thus submitted that in the present case also, the expenditure did not result in increase in the capacity or extra building space ... case of CIT vs. Oxford University Press reported in 108 ITR 166 has expounded that, the test for judging the nature of capital or revenue expenditure is to see whether as a result of expenditure what is being done is to preserve and maintain an already existing asset or whether

M/S Infosys Ltd, Bangalore vs. The Assistant Commissioner of Income Tax Circle-3(1)(1), Bangalore

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

ITA 1531/BANG/2017[2008-09]Status: DisposedITAT Bangalore30 Nov 2022AY 2008-09

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

carpets and refurbishing of hotel rooms in tune with international standards without addition of extra floor space or extra room capacity was allowable as revenue expenditure. The Ld.AR thus submitted that in the present case also, the expenditure did not result in increase in the capacity or extra building space ... case of CIT vs. Oxford University Press reported in 108 ITR 166 has expounded that, the test for judging the nature of capital or revenue expenditure is to see whether as a result of expenditure what is being done is to preserve and maintain an already existing asset or whether

Infosys Ltd, Bangalore vs. The Assistant Commissioner of Income Tax Circle-3(1)(1), Bangalore

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

ITA 1530/BANG/2017[2007-08]Status: DisposedITAT Bangalore30 Nov 2022AY 2007-08

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

carpets and refurbishing of hotel rooms in tune with international standards without addition of extra floor space or extra room capacity was allowable as revenue expenditure. The Ld.AR thus submitted that in the present case also, the expenditure did not result in increase in the capacity or extra building space ... case of CIT vs. Oxford University Press reported in 108 ITR 166 has expounded that, the test for judging the nature of capital or revenue expenditure is to see whether as a result of expenditure what is being done is to preserve and maintain an already existing asset or whether

Asst.C.I.T., Bangalore vs. M/S Infosys Ltd., Bangalore

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

ITA 613/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

carpets and refurbishing of hotel rooms in tune with international standards without addition of extra floor space or extra room capacity was allowable as revenue expenditure. The Ld.AR thus submitted that in the present case also, the expenditure did not result in increase in the capacity or extra building space ... case of CIT vs. Oxford University Press reported in 108 ITR 166 has expounded that, the test for judging the nature of capital or revenue expenditure is to see whether as a result of expenditure what is being done is to preserve and maintain an already existing asset or whether

Infosys Ltd, Bangalore vs. Assistant Commissioner of Income Tax, Bangalore

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

ITA 532/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

carpets and refurbishing of hotel rooms in tune with international standards without addition of extra floor space or extra room capacity was allowable as revenue expenditure. The Ld.AR thus submitted that in the present case also, the expenditure did not result in increase in the capacity or extra building space ... case of CIT vs. Oxford University Press reported in 108 ITR 166 has expounded that, the test for judging the nature of capital or revenue expenditure is to see whether as a result of expenditure what is being done is to preserve and maintain an already existing asset or whether

Dy.C.I.T., Bangalore vs. M/S Infosys Limited, Bangalore

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

ITA 509/BANG/2015[2010-11]Status: DisposedITAT Bangalore30 Nov 2022AY 2010-11

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

carpets and refurbishing of hotel rooms in tune with international standards without addition of extra floor space or extra room capacity was allowable as revenue expenditure. The Ld.AR thus submitted that in the present case also, the expenditure did not result in increase in the capacity or extra building space ... case of CIT vs. Oxford University Press reported in 108 ITR 166 has expounded that, the test for judging the nature of capital or revenue expenditure is to see whether as a result of expenditure what is being done is to preserve and maintain an already existing asset or whether

Infosys Ltd., Bangalore vs. DCIT, Bangalore

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

ITA 449/BANG/2015[2010-11]Status: DisposedITAT Bangalore30 Nov 2022AY 2010-11

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

carpets and refurbishing of hotel rooms in tune with international standards without addition of extra floor space or extra room capacity was allowable as revenue expenditure. The Ld.AR thus submitted that in the present case also, the expenditure did not result in increase in the capacity or extra building space ... case of CIT vs. Oxford University Press reported in 108 ITR 166 has expounded that, the test for judging the nature of capital or revenue expenditure is to see whether as a result of expenditure what is being done is to preserve and maintain an already existing asset or whether

Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore vs. M/S. Wipro Ge Medical Systems Limited, Bangalore

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

ITA 1020/BANG/2007[2000-01]Status: DisposedITAT Bangalore30 Nov 2022AY 2000-01

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2000-01 M/S. Wipro Ge The Deputy Medical Systems Ltd., Commissioner Of Plot No. 4, Kadugodi Income Tax, Indl. Area, Central Circle – Sadaramangala, 1(3), Vs. Bangalore – 560 067. Bangalore. Pan: Aaacw1685G Appellant Respondent : Shri K.R. Pradeep & Assessee By Smt. Girija G.P., Advocates : Shri K.R. Narayana, Addl. Revenue By Cit-Dr Date Of Hearing : 21-10-2022 Date Of Pronouncement : 30-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Remand By Hon'Ble Karnataka High Court In Ita No. 1058/2008 Vide Order Dated 02/12/2016 In An Appeal Filed By Revenue. 2. The Ld.Ar Submitted That Revenue Filed Appeal Before The Hon’Ble Karnataka High Court Against Order Dated 20/06/2008 Passed By This Tribunal On Following Issues. 1) Reduction In Claim Of Exemption Of Profits U/S. 10A. 2) Reduction In Claim U/S. 80Hhe.

For Respondent: Shri K.R. Pradeep &
Section 10ASection 80HSection 80I

Reduction in claim u/s. 80HHE. Page 2 3) Reduction of claim u/s. 80IB 4) Disallowance of non-compete fee paid as a revenue expenditure 3. Hon’ble High Court while dealing with the above issues framed the following questions of law. “(i) Whether the appellate authorities were correct in holding ... assessing Officer that the non- competition fee of Rs.1,18,14,504/- paid in respect of Marquette range of products was not a revenue expenditure and consequently the claim of ¼ of the same being written off in the accounts amounting to Rs.29,53,625/- during the current assessment year

Petronet Mhb Limited, Bangalore vs. The Income Tax Officer, Ward-5(1)(3), Bangalore

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

ITA 789/BANG/2022[2013-14]Status: DisposedITAT Bangalore28 Nov 2022AY 2013-14

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2013-14

For Appellant: Shri M.G Vinay Simha, C.AFor Respondent: Shri K.R Narayana, Addl. CIT (DR)
Section 143(3)Section 154Section 37(1)

consideration, the assessee incurred an expenditure of Rs.1,17,49,470 towards Corporate Social Responsibility (CSR) activities and the same has been claimed as revenue expenditure. The assessee submitted before the AO that as a good corporate citizen and as a measure of gaining goodwill of the people living around

M/S. Sartorius Stedim India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle- 6(1)1), Bangalore

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

ITA 1695/BANG/2019[2012-13]Status: DisposedITAT Bangalore28 Nov 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 1695/Bang/2019 Assessment Year : 2012-13 M/S. Sartorius Stedim India Pvt. Ltd., The Assistant No. 69/2 & 69/3, Commissioner Of Kunigal Road, Income Tax, Jakkasandra, Circle – 6(1)(1), Nelamangala, Vs. Bangalore. Bengaluru – 562 123. Pan: Aabcs7591Q Appellant Respondent : Shri Narendra Kumar Jain, Assessee By Ca : Shri Venudhar Godesi, Revenue By Jcit-Dr Date Of Hearing : 28-10-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 20/05/2019 Passed By The Ld.Cit(A) For A.Y. 2012-13 On Following Grounds Of Appeal: “General Ground 1. The Order Of The Learned Commissioner Of Income Tax (Appeals)-6 (Hereinafter Referred To As Cit(A)) To The Extent Prejudicial To The Appellant Is Bad In Law. Transfer Pricing - General Grounds 2. The Learned Cit(A) Has Erred In Confirming The Action Of The Ao & Tpo In: A) Making A Reference For The Determination Of The Arm'S Length Price Of The International Transactions To The Tpo

For Respondent: Shri Narendra Kumar Jain

applicable on assets capitalised and depreciation claimed thereon. 14. The learned CIT(A) has erred in concluding that purchase of software is revenue expenditure without appreciating the facts and circumstances of the case and without giving an opportunity to the Appellant The Appellant submits that each of the above grounds ... absence of any requirement of law for making deduction of tax out of expenditure, which has been capitalized and no amount was claimed as revenue expenditure, no disallowance under Section 40(a)(i) and (ia) of the Act would be made. It is also pertinent to note that depreciation

M/S Infosys Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 718/BANG/2017[2012-13]Status: DisposedITAT Bangalore28 Nov 2022AY 2012-13

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

Section 10ASection 14ASection 2Section 2(24)Section 40

under consideration against which no TDS was deducted. 4.7.3. Assessee had also incurred an amount in respect of software expenses which was claimed as revenue expenditure at Rs.462,77,39,077/-. 4.7.4. Brand building expenses was incurred by assessee to the tune of Rs.81,79,53,112/- for the year ... submitted that, following the direction of this Tribunal, the Ld.AO passed the OGE to ITAT order on 3.9.2019 and allowed the software expenses as revenue expenditure. 11.5. The Ld.AR submitted that the software expenses were for software licenses in respect of application software. It was not in Page

ACIT- Circle-6(2)(1), Mumbai vs. Cg Power & Industrial Solution Ltd. (Formerly Known As Crompton Greaves Ltd.), Mumbai

In the result, the appeal filed by the assessee is treated as allowed and the appeal of the revenue is dismissed

ITA 2955/MUM/2018[2010-11]Status: DisposedITAT Mumbai25 Nov 2022AY 2010-11
Section 14Section 14ASection 35Section 80I

known as Crompton Greaves Ltd.) 16. The assessee also put up an additional claim before Ld CIT(A). It was explained that the eligible revenue expenditure incurred by the assessee was Rs. 30.92 crores, whereas the assessee had claimed deduction on the amount of Rs. 22.22 crores only. Accordingly ... denied on Account of non-approval 318 lakhs 8 M/s. CG Power & Industrial Solution Ltd. (formerly known as Crompton Greaves Ltd.) (C) Total revenue expenditure claimed by the assessee in ROI 2222 lakhs (-) Certified by DSIR 1898 lakhs --------------- 324 lakhs --------------- Weighted deduction of 50% denied on Account of non-approval

Jm Morgan Stanley Securities P. Ltd, Mumbai vs. Addl CIT 4(3), Mumbai

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

ITA 7118/MUM/2010[2006-07]Status: DisposedITAT Mumbai25 Nov 2022AY 2006-07

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Sunil M. LalaFor Respondent: Ms. Vatsalaa Jha
Section 143(3)Section 144C(13)Section 144C(5)Section 14ASection 40Section 40A(2)

assessee in its books of accounts as principal amount for acquiring ‘finance lease assets’ is capital expenditure and not eligible for deduction as revenue expenditure. Further, the AO held that the interest payment as finance charges on lease- finance assets, which were debited to the profit and loss account

M/S Ge T&D India Limited, Chennai vs. DCIT Large Tax Payer Unit 1, Chennai

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

ITA 725/CHNY/2018[2010-11]Status: DisposedITAT Chennai23 Nov 2022AY 2010-11

Bench: Shri Mahavir Singhand Shri G. Manjunathaआयकरअपीलसं./Ita No.: 725/Chny/2018 िनधा"रण वष"/Assessment Year: 2010 - 11 Ge T&D India Ltd., The Dcit, 19/1, Ioc Building, Gst Road, Vs. Large Tax Payer Unit-1, Pallavaram, Chennai Chennai – 600 043. Pan: Aaacg 2115R (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Sriram Seshadhri, C.A ""यथ" क" ओर से/Respondent By : Shri S. Marudhu Pandian, Cit सुनवाई क" तार"ख/Date Of Hearing : 17.11.2022 घोषणा क" तार"ख/Date Of Pronouncement : 23.11.2022 आदेश /O R D E R

For Appellant: Shri Sriram Seshadhri, C.A ""For Respondent: Shri S. Marudhu Pandian, CIT
Section 143(3)Section 148

Padappai By citing the following decisions, it was replied that any expenses incurred even for setting up a new factory shall be treated as revenue expenditure:- a) CIT Vs. Rane Madras 2007 TIOL 551 (HC Madras) b) Jay Engineering Works Vs CIT 2008 166 Taxmann 115 (HC Delhi) c) JCIT ... that the expenditure incurred on shifting the factory premises under compelling circumstances, viz., for very survival of the, factory itself could be allowed as revenue expenditure. But, in the case of the assessee, the moving out expenses relates to the existing facility being located to another location for ease

ACIT Large Tax Payer Unit 2, Chennai vs. M/S India Japan Lighting Limited, Chennai

In the result, the appeals filed by the Revenue are

ITA 719/CHNY/2018[2014-15]Status: DisposedITAT Chennai23 Nov 2022AY 2014-15

Bench: Shri Mahavir Singh & Shri G. Manjunathaआयकरअपीलसं./Ita Nos.: 718 & 719/Chny/2018 िनधा"रणवष" / Assessment Years: 2011-12 & 2014-15

For Appellant: Shri. AR V Sreenivasan, Addl. CITFor Respondent: Shri. N V Balaji, Advocate
Section 143(3)Section 14A

submissions. The question raised is regarding payment of royalty to Koito Manufacturing Ltd., Japan. Whether such royalty paid could be allowed in full as revenue expenditure or whether it had to be considered as a capital outgo, was an issue before this Tribunal in assessee’s appeals for assessment years ... before us. It was argued on behalf of the assessee that in assessment year 2003-04, the Department has itself accepted this expenditure as revenue expenditure and has allowed the same as deduction u/s 35(2AB). This fact could not be successfully controverted from the side of the Revenue

ACIT Large Tax Payer Unit 2, Chennai vs. M/S India Japan Lighting Limited, Chennai

In the result, the appeals filed by the Revenue are

ITA 718/CHNY/2018[2011-12]Status: DisposedITAT Chennai23 Nov 2022AY 2011-12

Bench: Shri Mahavir Singh & Shri G. Manjunathaआयकरअपीलसं./Ita Nos.: 718 & 719/Chny/2018 िनधा"रणवष" / Assessment Years: 2011-12 & 2014-15

For Appellant: Shri. AR V Sreenivasan, Addl. CITFor Respondent: Shri. N V Balaji, Advocate
Section 143(3)Section 14A

submissions. The question raised is regarding payment of royalty to Koito Manufacturing Ltd., Japan. Whether such royalty paid could be allowed in full as revenue expenditure or whether it had to be considered as a capital outgo, was an issue before this Tribunal in assessee’s appeals for assessment years ... before us. It was argued on behalf of the assessee that in assessment year 2003-04, the Department has itself accepted this expenditure as revenue expenditure and has allowed the same as deduction u/s 35(2AB). This fact could not be successfully controverted from the side of the Revenue

DCIT Cent. Cir 1(2), Mumbai vs. M/S. Hiranandani Construction Pvt. Ltd, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 1849/MUM/2021[2016-17]Status: DisposedITAT Mumbai22 Nov 2022AY 2016-17

Bench: Shri M Balaganesh & Shri Pavan Kumar Gadaledcit, Vs. M/S. Hiranandani Central Circle – 1(2) Constructions Pvt Ltd 906, 9Th Floor, Pratishta 511, Dalmal Towers, Bhavan, Old Cgo Bldg 211, Nariman Point, (Annexe), Mk Road, Mumbai – 400021. Mumbai – 400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaach0409H Appellant .. Respondent Appellant By : Shri Tejinder Pal Singh Anand, Sr Dr Respondent By : Shri K Gopal Sr. Adv & Shri Om Kandalkar, Adv Date Of Hearing 03.11.2022 Date Of Pronouncement 15.11.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Revenue Has Filed The Appeal Against The Order Passed By The Commissioner Of Income Tax (Appeals)(Cit(A)-47, Mumbai Passed U/S 143(3) & 250 Of The Act. The Revenue Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Tejinder Pal SinghFor Respondent: Shri K Gopal Sr. Adv and Shri Om Kandalkar, Adv
Section 143(1)Section 143(2)Section 143(3)

Constructions Pvt Ltd, Mumbai. particular profit and loss account found that the assessee has debited expenses related to construction activities and was claimed as revenue expenditure, where the assessee has not transferred these expenses to construction work in progress(WIP). The assessee has been following the projection completion method ... opinion that the expenses should be part of the construction and work in progress and accordingly the claim of revenue expenditure was disallowed and treated as the part of the work in progress and made addition of Rs. 23,49,034/-. 3. The second disputed issue the AO found that

M/S United Spirits Limited, Bangalore vs. Joint Commissioner of Income Tax Special Range-7, Bangalore

In the result, ground 7 is allowed for statistical purposes

ITA 3091/BANG/2018[2014-15]Status: DisposedITAT Bangalore22 Nov 2022AY 2014-15

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.3091/Bang/2018 : Asst.Year 2014-2015 M/S.United Spirits Limited The Joint Commissioner Of 6Th Floor, Ub Towers, Income-Tax, Special Range-7 V. Bangalore. # 24 Vittal Mallya Road Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent)

For Appellant: Sri.Percy Pardiwala, Senior Counsel and Sri.Ankur Pai, AdvocateFor Respondent: Sri. Manjunath Karkihalli, CIT –DR
Section 115PSection 143(2)Section 143(3)Section 14ASection 234BSection 36(1)(iii)Section 92C

case of Samudra Developers Pvt Ltd (ITA 5974/Mum/2013 dated 26- 04-2017) and it was held that the same is allowable as revenue expenditure. For the sake of convenience, we extract below the operative portion of the order passed by Mumbai bench of Tribunal on an identical issue:- “3. Second ... group with a view to get visibility, that it was in nature of some kind of advertisement expenditure, that same should be allowed as revenue expenditure. Referring to the case of Delhi Cloth and General Mills Co.Ltd.(115 ITR 659) of the honorable Delhi High Court, the FAA allowed

DCIT Cent. Cir 8(3), Mumbai vs. M/S 63 Moon Technologies India Ltd, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 1515/MUM/2022[2011-12]Status: DisposedITAT Mumbai21 Nov 2022AY 2011-12

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Sukhsagar SyalFor Respondent: M/s. Vatsalaa Jha
Section 250

mercantile methods of accounting. Assessee has also referred to CBDT notifications which confirms that expenses incurred for raising issue of debentures is allowable as revenue expenditure. Further Page No. 45 of CBDT circular No. 56 has been referred for proposition that the provision for amortization is not intended to supersede