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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

ACIT-3(1)(1), Mumbai, Ayakar Bhawan vs. Samsonite South Asia Pvt Ltd, Andheri

In the result, appeal of the Revenue is dismissed

ITA 4278/MUM/2025[2010-11]Status: DisposedITAT Mumbai30 Sept 2025AY 2010-11

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2010-11 Assistant Commissioner Of Samsonite South Asia Pvt. Ltd. Income Tax 3(1)(1) 402/Ackruti Star, Midc, 607, Ayakar Bhawan, M.K. Andheri East, Vs. Road, Mumbai – 400093 Mumbai - 400020 (Pan: Aaacs8598L) (Appellant) (Respondent) Present For: Assessee : Jitendra Singh, Advocate Revenue : Shri Surendra Mohan, Sr. Dr Date Of Hearing : 12.08.2025 Date Of Pronouncement : 30.09.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2025-26/1075686655(1), Dated 21.04.2025, Passed Against The Order By Additional Commissioner Of Income Tax 8(3), Mumbai U/S.143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 30.03.2014, For Assessment Year 2010- 11. 2. Grounds Taken By The Revenue Are Reproduced As Under: (1) Whether On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Is Correct In Allowing The Entire Amount Of Rs.7,32,38,757/- Incurred By The Assessee For Building Of ‘Samsonite’ Brand Without Appreciating The Fact That These Expenses Were Incurred Towards Creating Intangible Rights In Its Favour Which Are Capable Of Giving Enduring Benefits To The Assessee Company & Hence Are Assignable Over A Number Of Year?

For Appellant: Jitendra Singh, AdvocateFor Respondent: Shri Surendra Mohan, Sr. DR
Section 143(3)

reason assigned by the Tribunal for interference. 6. The Tribunal has also correctly observed that there was no question of deferred revenue expenditure. This view of the Tribunal aligns with the decision of the Hon'ble Supreme Court in Tapadia Tools Ltd. Vs. Joint Commissioner of Income Tax, Nashik, particularly ... incurred by assessee-company on corporate advertisement to maintain its corporate image which resulted in increased sale of products, was to be allowed as revenue expenditure. 7 Samsonite South Asia Pvt. Ltd. Assessment Year 2010-11 (ii) Expire Jute Co. Ltd. v. CIT (1980) 124 ITR 1(SC) Proposition: Even

Madresa Mohammadiyan and Panjataniya, Dahod Gujarat vs. CIT(E), Ahmedabad

In the result the appeal filed by the assessee is dismissed

ITA 1118/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad26 Sept 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2017-18 Madressa Mohammadiyn & Cit(Exemption) Panjataniya, Madresa Raildings Nehru Bridge B/H. Tower Talav Road, Dahod. Ahmedabad. Pan : Brdmo 8620 D (Applicant) (Responent) : Shri Ankit Chokshi, Ar Assessee By : Shri Sher Singh, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 24/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 26/09/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Sher Singh, CIT-DR
Section 10Section 11Section 12A(1)(b)Section 133(6)Section 139(1)Section 142(1)Section 144Section 144BSection 144B(1)(xii)Section 263

been filed and the requirements of section 12A(1)(b) were not fulfilled and further proposed to disallow 30 percent of revenue expenditure of Rs.1,57,18,133/- for want of supporting vouchers, as well as to disallow capital expenditure of Rs. 44,68,533/- for non-production of bills ... report was not available on the e-filing portal and that bills produced included hand- made and self-made vouchers, restricted the disallowance of revenue expenditure to 15 percent, observing that vouchers aggregating to Rs.17,12,780/- had been produced against the total claim and denied exemption under section