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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

Acc India Pvt.Ltd., New Delhi vs. ACIT, Circle-1(1) Delhi, Delhi

In the result, the appeal of the Revenue in ITA No

ITA 4907/DEL/2024[2015-16]Status: DisposedITAT Delhi24 Sept 2025AY 2015-16

Bench: Shri Mahavir Singh & Shri Amitabh Shuklaacit, Circle 1(1), Vs. Acc India Pvt. Ltd. 5Th Floor, 525, Basement, Room No. 159-A, C.R. Building, New Delhi Jasola, South Delhi, New Delhi -19 (Pan: Aalca9219Q) (Appellant) (Respondent) C.O. No. 72/Del/2023 (Ita No. 650/Del/2020) (Ay 2015-16) Acc India Pvt. Ltd. Vs. Acit, Circle 1(1), 5Th Floor, 525, Basement, New Delhi Jasola, South Delhi, New Delhi-19 (Pan: Aalca9219Q) (Appellant) (Respondent) Acc India Pvt. Ltd. Vs. Acit, Circle 1(1), 5Th Floor, 525, Basement, New Delhi Jasola, South Delhi, New Delhi-19 (Pan: Aalca9219Q) (Appellant) (Respondent) Revenue By : Sh. Ajay Kumar Arora, Sr. Dr. Assesseeby : Sh. K. Sampath, Adv. & Sh. V. Rajakumar, Adv.

For Appellant: Sh. K. Sampath, Adv. & Sh. V. Rajakumar, AdvFor Respondent: Sh. Ajay Kumar Arora, Sr. DR
Section 143(3)

foreclosure of various projects. He noted that this claim is in the nature of capital loss and cannot be allowed as revenue expenditure u/s 37(1) of the Act. Hence, he dismissed the assessee’s ground without going into the merits of the case. 14. Aggrieved the assessee is before ... year and that is why it is debited from the profits and loss account in the current year. Accordingly, the assessee claimed this as Revenue expenditure. The Assessing Officer after examining reply of the assessee noted that the expenditure is payable by the assessee to sub- contractor who raises

ACIT, Circle-1(1), New Delhi vs. Acc India Pvt. Ltd., Delhi

In the result, the appeal of the Revenue in ITA No

ITA 650/DEL/2020[2015-16]Status: DisposedITAT Delhi24 Sept 2025AY 2015-16

Bench: Shri Mahavir Singh & Shri Amitabh Shuklaacit, Circle 1(1), Vs. Acc India Pvt. Ltd. 5Th Floor, 525, Basement, Room No. 159-A, C.R. Building, New Delhi Jasola, South Delhi, New Delhi -19 (Pan: Aalca9219Q) (Appellant) (Respondent) C.O. No. 72/Del/2023 (Ita No. 650/Del/2020) (Ay 2015-16) Acc India Pvt. Ltd. Vs. Acit, Circle 1(1), 5Th Floor, 525, Basement, New Delhi Jasola, South Delhi, New Delhi-19 (Pan: Aalca9219Q) (Appellant) (Respondent) Acc India Pvt. Ltd. Vs. Acit, Circle 1(1), 5Th Floor, 525, Basement, New Delhi Jasola, South Delhi, New Delhi-19 (Pan: Aalca9219Q) (Appellant) (Respondent) Revenue By : Sh. Ajay Kumar Arora, Sr. Dr. Assesseeby : Sh. K. Sampath, Adv. & Sh. V. Rajakumar, Adv.

For Appellant: Sh. K. Sampath, Adv. & Sh. V. Rajakumar, AdvFor Respondent: Sh. Ajay Kumar Arora, Sr. DR
Section 143(3)

foreclosure of various projects. He noted that this claim is in the nature of capital loss and cannot be allowed as revenue expenditure u/s 37(1) of the Act. Hence, he dismissed the assessee’s ground without going into the merits of the case. 14. Aggrieved the assessee is before ... year and that is why it is debited from the profits and loss account in the current year. Accordingly, the assessee claimed this as Revenue expenditure. The Assessing Officer after examining reply of the assessee noted that the expenditure is payable by the assessee to sub- contractor who raises

Sahajanand Technologies Private Limted, Surat vs. The ACIT, Central Circle-4, Surat.

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

ITA 255/SRT/2025[2018-19]Status: DisposedITAT Surat23 Sept 2025AY 2018-19

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.255/Srt/2025 Assessment Year: 2018-19 (Hybrid Hearing) Sahajanand Technologies Pvt. Assistant Commissioner Of बनाम/ Ltd. Income-Tax, Central Circle-4, Vs. Building A1, Sahajanand Surat, Aaykar Bhawan, Majura Estate Vakharia Wadi, Nr. Gate, Surat-395 001 Dabholi Char Rasta, Surat- 395 004 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcs 4343 N (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Rajesh C. Shah, Ca राज" की ओर से /Respondent By Shri Aashish Pophare, Cit-Dr सुनवाई की तारीख/Date Of Hearing 11/08/2025 उद्घोषणा की तारीख/Date Of Pronouncement 23/09/2025

Section 143(3)Section 14ASection 250Section 35Section 35(1)(i)

Ministry of Science and Technology has allowed whole capital expenditure of Rs.30.15 lakhs for weighted deduction u/s 35(2AB); however, out of total revenue expenditure of Rs.2,70,09,468/-, it allowed Rs.2,45,25,000/-. Hence, the remaining amount of Rs.24,84,868/- was not considered for weighted deduction ... never said that the above expenses claimed by the assessee are bogus and not incurred for R&D purposes. Hence, the expenses are normal revenue expenditure, allowable u/s 35(1)(i) of the Act. 4. On the other hand, Ld. CIT-DR for the revenue relied on the orders

Ocl India Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee is partly allowed and appeal of the Revenue is allowed for statistical purpose

ITA 4068/DEL/2015[2007-08]Status: DisposedITAT Delhi23 Sept 2025AY 2007-08

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.4068/िद"ी/2015(िन.व. 2007-08) Dalmia Bharat Ltd., (Successor In The Interest Of Ocl India Ltd.) 11Th & 12Th Floor, Hansalaya Building, 15, Barakhamba Road, New Delhi 110001 ...... अपीलाथ"/Appellant Pan: Aabco-8750-F बनाम Vs. Deputy Commissioner Of Income Tax, ..... "ितवादी/Respondent Circle 19(1), C R Building New Delhi 110095 आअसं.3767/िद"ी/2015(िन.व. 2007-08) Assistant Commissioner Of Income Tax, Aayakar Bhawan, Uditnagar, Rourkela, ...... अपीलाथ"/Appellant Dist. Sundargarh, Odisha 769012 बनाम Vs. Dalmia Bharat Ltd., Successor Of Ocl India Ltd., 11Th & 12Th Floor, Hansalaya Building, 15, Barakhamba Road, New Delhi 110001 ..... "ितवादी/Respondent Pan: Aabco-8750-F

For Appellant: S/Shri Vijay Shah, Navin Verma &For Respondent: Shri Amaninder Singh Dhindsa &
Section 43(5)Section 43ASection 53A

grounds of appeal, the assessee vide application dated 18.05.2022 has raised additional grounds of appeal in respect of claim of pre operative expenses as Revenue expenditure and claim of additional depreciation in second and subsequent assessment years. Apart from above two issues, the assessee has raised two more additional grounds ... assessee vide application dated 18.05.2022 has raised five additional grounds of appeal, the same reads as under:- “2.0. Claim of pre-operative expenses as revenue expenditure [Rs. 2,78,56,090/-] 2.1. During the previous year relevant to assessment year 2007-08, an amount of Rs.2

DCIT, New Delhi vs. M/S Ocl India Pvt. Ltd., New Delhi

In the result, appeal of the assessee is partly allowed and appeal of the Revenue is allowed for statistical purpose

ITA 3767/DEL/2015[2007-08]Status: DisposedITAT Delhi23 Sept 2025AY 2007-08

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.4068/िद"ी/2015(िन.व. 2007-08) Dalmia Bharat Ltd., (Successor In The Interest Of Ocl India Ltd.) 11Th & 12Th Floor, Hansalaya Building, 15, Barakhamba Road, New Delhi 110001 ...... अपीलाथ"/Appellant Pan: Aabco-8750-F बनाम Vs. Deputy Commissioner Of Income Tax, ..... "ितवादी/Respondent Circle 19(1), C R Building New Delhi 110095 आअसं.3767/िद"ी/2015(िन.व. 2007-08) Assistant Commissioner Of Income Tax, Aayakar Bhawan, Uditnagar, Rourkela, ...... अपीलाथ"/Appellant Dist. Sundargarh, Odisha 769012 बनाम Vs. Dalmia Bharat Ltd., Successor Of Ocl India Ltd., 11Th & 12Th Floor, Hansalaya Building, 15, Barakhamba Road, New Delhi 110001 ..... "ितवादी/Respondent Pan: Aabco-8750-F

For Appellant: S/Shri Vijay Shah, Navin Verma &For Respondent: Shri Amaninder Singh Dhindsa &
Section 43(5)Section 43ASection 53A

grounds of appeal, the assessee vide application dated 18.05.2022 has raised additional grounds of appeal in respect of claim of pre operative expenses as Revenue expenditure and claim of additional depreciation in second and subsequent assessment years. Apart from above two issues, the assessee has raised two more additional grounds ... assessee vide application dated 18.05.2022 has raised five additional grounds of appeal, the same reads as under:- “2.0. Claim of pre-operative expenses as revenue expenditure [Rs. 2,78,56,090/-] 2.1. During the previous year relevant to assessment year 2007-08, an amount of Rs.2

DCIT, Circle-7(1), Delhi vs. Fmi Automotive Components Private Limited, Haryana

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

ITA 3489/DEL/2024[2017-18]Status: DisposedITAT Delhi22 Sept 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahmandcit, Circle 7 (1), Vs. Fmi Automotive Components Private Limited, Delhi. Plot No.1, Subplot 4, 5, 8 & 9 Msil, Supplier Park, Phase 3A, Imt Manesar, Gurgaon – 1222 050 (Haryana). (Pan :Aabcf1682P) (Appellant) (Respondent) Assessee By :Shri S.K. Agarwal, Ca Revenue By :Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 24.06.2025 Date Of Order : 22.09.2025 O R D E R Per S. Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 30.05.2024 For The Assessment Year 2017-18 Raising Following Grounds Of Appeal :- “1. Whether On The Facts & Circumstances Of The Case & In Law, The Ld Nfac Has Erred In Allowing The Appeal Of The Assessee By Deleting The Addition Made By The Ao Amounting To Rs.5,90,59,019/- On Account Of Disallowance Of Foreign Exchange Loss On Account Of Plant & Machinery.

For Appellant: Shri S.K. Agarwal, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 143(1)Section 143(2)Section 41

case, the Tribunal was right in holding that the expenditure incurred for replacing the petrol engine by diesel engine was in the nature of revenue expenditure for current repairs to the machinery of the assessee. 5.2 Madras High Court in the case of CIT vs Asher Textiles ... cannot be regarded as capital expenditure. Replacement of hardboard set on wooden frames with thermostat wood insulation boards set in aluminium frames was undoubtedly revenue expenditure and did not constitute capital expenditure. Therefore, the expenditure in question incurred by the assessee was to be allowed as a revenue expenditure

Township Real Estate Developers Private Limited, Mumbai vs. Principal Commissioner of Income Tax -6, Mumbai

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

ITA 3303/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Sept 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankartownship Real Estate V/S. Principal Commissioner Of Developers Private Limited, बनाम Income Tax– 6, Room No. C-62, Vibgyor Tower, Bandra 501, 5Th Floor, Aaykar Kurla Complex, Bandra - East, Bhawan, Maharishi Karve Mumbai –400 051, Maharashtra Road, Mumbai–400020, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabct7356E Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Nishith Khatri, ARFor Respondent: Shri Ritesh Misra, (CIT-DR)
Section 135Section 143(3)Section 144BSection 263Section 80G

revenue or capital expenditure. This argument predicates on the assessment order which apparently does not give any reasons while allowing the entire expenditure as revenue expenditure. However, that by itself would not be indicative of the fact that the Assessing Officer had not applied his mind on the issue. There ... Therefore, one has to see from the record as to whether there was application of mind before allowing the expenditure in question as revenue expenditure. Learned counsel for the assessee is right in P a g e | 8 A.Y. 2020-21 Township Real Estate Developers Private Limited his submission that

Diosma Lifesciences Private Limited, Mumbai vs. Income Tax Officer Ward 4(1) Thane, Thane

In the result, the appeal of the assessee is dismissed

ITA 4271/MUM/2025[2018-19]Status: DisposedITAT Mumbai16 Sept 2025AY 2018-19

Bench: Ms. Kavitha Rajagopal & Shri Prabhash Shankardiosma Lifesciences Private V/S. Income Tax Officer, Ward – Limited बनाम 4(1), Qureshi Mansion, Shop No. 77, C-Wing, Gokhale Road, Naupada, Harmony Mall Commercial Thane West, Thane - 400 Premises, Bhagat Singh Nagar 602, Maharashtra No.1, Link Road, Goregaon(West), Mumbai - 400 104, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aafcd0525R Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Vipul Shah, ARFor Respondent: Shri Aadesh Rai, Addl. CIT, (Virtually appeared)
Section 133(6)Section 143(2)Section 143(3)Section 37(1)

monetary grant from the pharmaceutical and allied health sector Industries. 3. Section 37(1) of Income Tax Act provides for deduction of any revenue expenditure (other than those failing under sections 30 to 36) from the business Income if such expense is laid out/expended wholly or exclusively for the purpose ... Private Limited cash or monetary grant from the pharmaceutical and allied health sector industries. Section 37(1) of the Act provides deduction of any revenue expenditure (other than those falling under sections 30 to 36) from the business income if such expense is laid out / expended wholly or exclusively

Smt Bertha D'Costa, Cavelossim, Goa vs. Income Tax Officer, Ward -2, Margao

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

ITA 159/PAN/2019[2015-16]Status: DisposedITAT Panaji15 Sept 2025AY 2015-16

Bench: Shri Pavan Kumar Gadalei T A. Nos.158 &159/Pan/2019 (A.Y. 2015-16 ) Shri.Julio D Costa, Vs Ito-Ward-2, H.No.337,Mobor,Cavelossim, Blessings Pioneer Salcete,Goa-403731. Complex, (Pan:Aewpd6709F) Old Market, Margoa-403601,Goa. Smt.Bertha D Costa, Ito-Ward-2, Vs H.No.337,Mobor,Cavelossim, Blessings Pioneer Salcete,Goa-403731. . Complex, (Pan:Aewpd6748N) Old Market, Margoa-403601,Goa. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Shrinivas Nayak.Ar Revenue By Smt.Manju Thakur.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.09.2025 घोषणा की तारीख/Date Of Pronouncement 15.09.2025 Order Per Pavan Kumar Gadale, Jm: These Two Appeals Are Filed By The Assesses (Husband & Wife) Against The Separate Orders Of The Cit(A) -1 Panaji Passed U/Sec143(3) & U/Sec 250 Of The Act. The Assesses Are Governed By The Portuguese Civil Code & Provisions Of Section 5A Of The Act. 2. Since The Issues Involved In These Two Appeals Are Common & Identical, Hence They Are Clubbed, Heard & Aconsolidated Order Is Passed. For The Sake Of Convenience

Section 44ASection 5A

these facts and information and availability of own funds of the assesse utilised in acquisition, the A.O has wrongly has interpreted the acquisition as revenue expenditure, but it is in the nature of capital expenditure. The assessee as per the accounting principles and policies has disclosed the trawler under fixed