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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, Central Circle - 1(3), Chennai vs. Casa Grande Homes Private Limited, Chennai

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

ITA 1709/CHNY/2025[2017-18]Status: DisposedITAT Chennai29 Oct 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1709/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of Vs. Casa Grande Homes Private Limited, New No. 111, Old No. 59, 6Th Floor, Income Tax, Central Circle 1(3), Thiruvanmiyur, Chennai 600 041. Chennai. [Pan:Aagcc1182Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. Gouthami Manivasagam, Jcit ""थ" की ओर से/Respondent By : Shri G. Reddi Prakash, Ca सुनवाई की तारीख/ Date Of Hearing : 17.09.2025 घोषणा की तारीख /Date Of Pronouncement : 29.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Revenue Is Directed Against The Order Dated 12.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) – 18, Chennai For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 44 Days. The Dcit Central Circle 1(3)(I/C), Chennai Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We Find The Reasons Stated By The Appellant-Revenue

For Appellant: Ms. Gouthami Manivasagam, JCITFor Respondent: Shri G. Reddi Prakash, CA
Section 145(2)

prevails for income computation. She vehemently argued that when no revenue was recognized, the indirect expenses attributable to the project cannot be claimed as revenue expenditure, but, must be capitalized to align with ICDS-III’s cost allocation principles. She further submits that the ld. CIT(A) failed to consider

Tata Teleservices Limited, Delhi vs. Assistant Commissioner of Income Tax, Circle 25(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 2549/DEL/2024[2017-18]Status: DisposedITAT Delhi27 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.2549/Del./2024, A.Y. 2017-18 Tata Teleservices Limited Assistant Commissioner Of Jeevan Bharati Tower-1, Income Tax, Circle-25(1), 10Th Floor, Vs. C. R. Building, I. P. Estate, 24, Connaught Circus New Delhi New Delhi Pan: Aaact2438A (Appellant) (Respondent) Appellant By Sh. Salil Kapoor, Advocate Ms. Ananya Kapoor, Advocate & Sh. Shivam Yadav, Advocate Respondent By Sh. Dayainder Singh Sidhu, Cit-Dr Date Of Hearing 30/07/2025 Date Of Pronouncement 27/10/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal Of The Assessee For Assessment Year (‘Ay’) 2017-18 Is Directed Against The Order Dated 29.03.2024 Of The Commissioner Of Income Tax (Appeals), Nfac, New Delhi [‘Cit(A)’].

Section 142(1)Section 143(3)Section 35DSection 37(1)

handset to customers at a price lower than the cost price to make the handsets, etc. The assessee claimed the customer acquisition cost as revenue expenditure as the same were incurred in normal course of business, which did not result any enduring benefit. Whereas the Ld. Assessing Officer (‘AO’) held ... been recognized as Customer Acquisition costs during the subject year." The assessee has claimed that customer acquisition cost is a revenue expenditure. The assessee has placed reliance on the following: Empire Jute Co. India Ltd. vs CIT [124 ITR 1] (SC) SBI Cards & Payment Services (P.) Ltd. Versus Commissioner