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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

The Ved Prakash Mukand Lal Educational Society, Yamunanagar vs. DCIT, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 824/CHANDI/2014[2005-06]Status: DisposedITAT Chandigarh10 Mar 2026AY 2005-06

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

account of the assessee showed that out of the total receipts of Rs.8,86,35,665/-, only a sum of Rs.7,06,25,737/- (revenue expenditure of Rs.3,67,90,756/- + capital expenditure of Rs.3,38,81,961/-) has been spent towards its objects, which approximately constitute only ... account of the assessee showed that out of the total receipts of Rs.8,86,35,665/-, only a sum of Rs.7,06,25,737/- (revenue expenditure of Rs.3,67,90,756/- + capital expenditure of Rs.3,38,81,961/-) has been spent towards its objects, which approximately formed only

ACIT, Circle 5(1), Chandigarh vs. M/S Venus Remedies Ltd., Chandigarh

The appeal of the revenue stand dismissed

ITA 742/CHANDI/2009[2006-07]Status: DisposedITAT Chandigarh09 Mar 2026AY 2006-07

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.742/Chandi/2009 (िनधा"रणवष" / Assessment Year: 2006-07) Acit Circle 5(1) M/S Venus Remedies Ltd. बनाम/ Vs. Sco 40-41, Sector 17-A Sco 39, Sector – 26 Chandigarh – 160017 Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacv-6524-H (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant : Sh. Parikshit Aggarwal (Ca), Sh. Jaspal Sharma (Advocate)&Ms. Shruti Khandelwal (Advocate) – By Ld. Ars ""थ"कीओरसे/Respondent By : Sh. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 02.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 09.03.2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeal For Assessment Year (Ay) 2006-07 Has Come Up For Hearing Before Us Pursuant To The Directions Of Hon’Ble Punjab & Haryana High Court In Revenue’S Appeal Ita No.81-2012 Dated 25-07-2024 Wherein Following Substantial Questions Of Law Were Determined: - 1. Weather On The Facts & In The Circumstances Of The Case, The Hon’Ble Itat Was Right In Upholding The Decision Of Ld. Cit(A) Who Directed The Ao To Reallocate The Expenses On Sales Ratio & To Reduce The Addition To Rs.142.24 Lacs As Against The Addition Of Rs.7,61,96,306/- On Account Of Unexplained Expenditure U/S 69C?

For Appellant: Sh. Parikshit Aggarwal (CA), Sh. Jaspal SharmaFor Respondent: Sh. Yamini (CIT) - Ld. DR (Virtual)
Section 35(2)Section 4Section 69CSection 80I

Selling & Distribution (except excise duty) -- 198.06 13.97 212.03 R&D Expenses -- 87.86 -- 87.86 Capital expenditure on R&D u/s 35(2) -- 300.67 -- 300.67 Deferred revenue expenditure on R&D u/s 35(2) -- 155.36 -- 155.36 9 Assessment Year: 2006-07 -- 1057.32 42.40 1099.72 Percentage (%) -- 96.14 3.86 100.00 Expenditure in sales ratio ... Total Financial Costs 1,93,15,643/- Depreciation 1,63,04,928/- Capital expenditure on R&D u/s 35(2) 300,67,328/- Deferred revenue expenditure on R&D u/s 35(2) 155,36,344/- From the adjudication of Ld. CIT (as extracted by us in preceding para

Mumbai International Airport Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 2(2)(1), Mumbai

The appeal of the assessee is allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

ITA 6692/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2014-15 Mumbai International Vs. Dcit, Circle – 2(2)(1) Airport Ltd., Aayakar Bhavan, Mk Road 1St Floor, Terminal-1B, New Marine Lines, Mumbai – Chhatrpati Shivaji 400020. International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) A.Y:2014-15 Dcit, Circle – 2(2)(1) Vs. Mumbai International Aayakar Bhavan, Mk Road Airport Ltd., New Marine Lines, Mumbai – 1St Floor, Terminal-1B, 400020. Chhatrpati Shivaji International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) Assessee By Shri Saurabha Soparkar Virtually Appeared Revenue By Shri Annavaram Kosuri, Sr. Ar Date Of Hearing 25.02.2026 Date Of Pronouncement 09.03.2026 आदेश / Order Per Makarand V Mahadeokar, Am: These Cross Appeals Are Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals) Under Section 250 Of The Mumbai International Airport Ltd., Mumbai Income-Tax Act, 1961 Dated 05.08.2025 In The Case Of The Assessee For Assessment Year 2014–15. The Assessment In The Present Case Was Originally Completed By The Assessing Officer Under Section 143(3) Of The Act Vide Order Dated 30.12.2017. Since The Issues Involved In The Appeals Of The Revenue As Well As The Assessee Arise Out Of The Same Appellate Order Of The Ld. Cit(A), These Appeals Were Heard Together & Are Being Disposed Of By Way Of This Common Order For The Sake Of Convenience & Brevity.

Section 143(3)Section 14ASection 250Section 28Section 32(1)(ii)Section 35D

held that the payment made to AAI towards retirement compensation of employees was allowable as revenue expenditure and that the provisions of section 35DDA were not applicable, since the payment was made to AAI under contractual obligations and not under any voluntary retirement scheme floated by the assessee ... been deducted at source during the impugned assessment year but claimed remaining sum of Rs. 154,23,19,088/- as revenue expenditure. The Assessing Officer was of the view that the assessee is eligible only for one fifth of Rs. 154,23,19,088/- as per the provisions of section

Deputy Commssioner of Income Tax (Central Circle) -3(3), Mumbai vs. M/S. Welspun Enterprises Limited, Mumbai

In the result, the appeal is dismissed

ITA 1823/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 Mar 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Arun Khodpiady. Cit (Central Circle)-3(3) M/S. Welspun Enterprises Limited 4Th Floor, Welspun House, Room No. 404, Kautilya Bhavan, Bkc, Mumbai-400 051 Senapati Bapat Marg, Lower Parel, Vs. Delisle Road, S.O., Mumbai-400 013 Pan/Gir No. Aabcm 4107 C (Appellant) : (Respondent) Appellant By : Shri Harsh Kapadia & Shri Ajay Nagpal Respondent By : Shri Arun Kanti Datta – Cit Dr Date Of Hearing : 28.01.2026 Date Of Pronouncement : 06.03.2026 O R D E R Per Saktijit Dey: Captioned Appeal By The Department, Arises Out Of Order Dated 17.01.2025 Of Learned Commissioner Of Income Tax (Appeals), Mumbai, Pertaining To A.Y. 2015-16. 2. In Ground No. 1, The Department Has Challenged The Deletion Of Addition Of Rs.23,47,354/-, Being Addition Made By The Assessing Officer (A.O. For Short) On Account Of Alleged Non-Genuine Expenses.

For Appellant: Shri Harsh Kapadia &For Respondent: Shri Arun Kanti Datta – CIT DR
Section 115JSection 132Section 153ASection 37(1)

decision arrived at by the ld.CIT(A).Section 37(1) of the Act is a residual provision that allows businesses to deduct revenue expenditures not specifically covered under Sections 30 to 36, provided they meet certain conditions. The primary condition is that the expense must not be a capital