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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(2), Bangalore vs. M/S. Manipal Hospitals (Bangalore) Private Limited, Bengaluru

In the result appeal of the Ld

ITA 959/BANG/2025[2012-13]Status: DisposedITAT Bangalore30 Jul 2025AY 2012-13

Bench: Shri Prashant Maharishi, Hon’Ble & Shri Soundararajan K, Hon’Bledcit – Central Circle – 1(2) Vs. M/S. Manipal Hospitals Room No. 307, 3Rdfloor. (Bangalore) Private Limited C.R. Building, Queens Road 98/2, The Annex Bengaluru – 560001 Ruso Bagh Karnataka Off. Hal Airport Road Bengaluru – 560017 Karnataka Pan: Aaccv9562D (Applicant) (Respondent) Assessee Represented By: Sri S.K. Tulsiyan, Advocate Department Represented By: Smt Prajakta Thakur, Jcit Date Of Hearing:09.07.2025 Date Of Pronouncement 30.07.2025 O R D E R Per Prashant Maharishi: 1. Captioned Appeal Is Filed By Dcit – Central Circle – 1(2), Bengaluru Against The Appellate Order Passed By The Commissioner Of Income Tax (Appeals)-15, Bengaluru (“The Ld.Cit(A)”) Dated 28.02.2025 Wherein The Appeal Filed By The Assessee Against The Penalty Order Dated 25.03.2022 Passed By Dcit – Central

Section 143(3)Section 271(1)(c)Section 37

with respect to the interest expenditure was made treating the above interest expenditure as pre-operative expenditure which was claimed by the assessee as revenue expenditure. Consequently, penalty notices were 3 M/s. Manipal Hospitals (Bangalore) Private Limited issued under section 271(1)(c) of the Act for furnishing inaccurate particular ... levy of penalty on the merits was with respect to treatment of interest payment of Rs.2,15,00,000/- claimed by the assessee as revenue expenditure but according to the Ld. AO same was pre-operative expenditure. Thus, there was a disallowance of this interest income but treated

DCIT, Circle-1(1), Vijayawada vs. Transmission Corporation of Andhra Pradesh Limited, Vijayawada

In the results, appeals filed by the revenue in ITA Nos

ITA 343/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2022-23

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23) Dcit – Circle – 1(1) Vs. Transmission Corporation Of Cr Buildings, M.G. Road Andhra Pradesh Limited Vijayawada – 520002 48-12-4/1, Gunadala Andhra Pradesh Vijayawada – 520004 Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) सी.ओ सं. / C.O. Nos. 30, 31, 32, 33, 34 & 35/Viz/2025 [आयकर अपीलसं.से उत्पन्न/I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23)] Transmission Corporation Of Vs. Dcit – Circle – 1(1) Andhra Pradesh Limited Cr Buildings, M.G. Road 48-12-4/1, Gunadala Vijayawada – 520002 Vijayawada – 520004 Andhra Pradesh Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri M. Chandramouleswara Rao, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

considered the above submissions and held that the expenditure incurred by the assessee towards restoration of transmission infrastructure damaged during the HUDHUD cyclone as revenue expenditure allowable under provisions of section 37(1) of the Act. He therefore pleaded that order of the Ld. CIT(A) be upheld ... Andhra Pradesh Limited expenditure, the Company has charged it to the Profit & Loss Account during the impugned assessment year and claimed as the revenue expenditure. It was also submitted by the Ld.AR that as and when the reimbursement from the Government of Andhra Pradesh is received it will be offered

DCIT, Circle-1(1), Vijayawada vs. Transmission Corporation of Andhra Pradesh Limited, Vijayawada

In the results, appeals filed by the revenue in ITA Nos

ITA 342/VIZ/2025[2021-22]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2021-22

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23) Dcit – Circle – 1(1) Vs. Transmission Corporation Of Cr Buildings, M.G. Road Andhra Pradesh Limited Vijayawada – 520002 48-12-4/1, Gunadala Andhra Pradesh Vijayawada – 520004 Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) सी.ओ सं. / C.O. Nos. 30, 31, 32, 33, 34 & 35/Viz/2025 [आयकर अपीलसं.से उत्पन्न/I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23)] Transmission Corporation Of Vs. Dcit – Circle – 1(1) Andhra Pradesh Limited Cr Buildings, M.G. Road 48-12-4/1, Gunadala Vijayawada – 520002 Vijayawada – 520004 Andhra Pradesh Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri M. Chandramouleswara Rao, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

considered the above submissions and held that the expenditure incurred by the assessee towards restoration of transmission infrastructure damaged during the HUDHUD cyclone as revenue expenditure allowable under provisions of section 37(1) of the Act. He therefore pleaded that order of the Ld. CIT(A) be upheld ... Andhra Pradesh Limited expenditure, the Company has charged it to the Profit & Loss Account during the impugned assessment year and claimed as the revenue expenditure. It was also submitted by the Ld.AR that as and when the reimbursement from the Government of Andhra Pradesh is received it will be offered

DCIT, Circle-1(1), Vijayawada vs. Transmission Corporation of Andhra Pradesh Limited, Vijayawada

In the results, appeals filed by the revenue in ITA Nos

ITA 341/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23) Dcit – Circle – 1(1) Vs. Transmission Corporation Of Cr Buildings, M.G. Road Andhra Pradesh Limited Vijayawada – 520002 48-12-4/1, Gunadala Andhra Pradesh Vijayawada – 520004 Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) सी.ओ सं. / C.O. Nos. 30, 31, 32, 33, 34 & 35/Viz/2025 [आयकर अपीलसं.से उत्पन्न/I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23)] Transmission Corporation Of Vs. Dcit – Circle – 1(1) Andhra Pradesh Limited Cr Buildings, M.G. Road 48-12-4/1, Gunadala Vijayawada – 520002 Vijayawada – 520004 Andhra Pradesh Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri M. Chandramouleswara Rao, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

considered the above submissions and held that the expenditure incurred by the assessee towards restoration of transmission infrastructure damaged during the HUDHUD cyclone as revenue expenditure allowable under provisions of section 37(1) of the Act. He therefore pleaded that order of the Ld. CIT(A) be upheld ... Andhra Pradesh Limited expenditure, the Company has charged it to the Profit & Loss Account during the impugned assessment year and claimed as the revenue expenditure. It was also submitted by the Ld.AR that as and when the reimbursement from the Government of Andhra Pradesh is received it will be offered

DCIT, Circle-1(1), Vijayawada vs. Transmission Corporation of Andhra Pradesh Limited, Vijayawada

In the results, appeals filed by the revenue in ITA Nos

ITA 340/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23) Dcit – Circle – 1(1) Vs. Transmission Corporation Of Cr Buildings, M.G. Road Andhra Pradesh Limited Vijayawada – 520002 48-12-4/1, Gunadala Andhra Pradesh Vijayawada – 520004 Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) सी.ओ सं. / C.O. Nos. 30, 31, 32, 33, 34 & 35/Viz/2025 [आयकर अपीलसं.से उत्पन्न/I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23)] Transmission Corporation Of Vs. Dcit – Circle – 1(1) Andhra Pradesh Limited Cr Buildings, M.G. Road 48-12-4/1, Gunadala Vijayawada – 520002 Vijayawada – 520004 Andhra Pradesh Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri M. Chandramouleswara Rao, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

considered the above submissions and held that the expenditure incurred by the assessee towards restoration of transmission infrastructure damaged during the HUDHUD cyclone as revenue expenditure allowable under provisions of section 37(1) of the Act. He therefore pleaded that order of the Ld. CIT(A) be upheld ... Andhra Pradesh Limited expenditure, the Company has charged it to the Profit & Loss Account during the impugned assessment year and claimed as the revenue expenditure. It was also submitted by the Ld.AR that as and when the reimbursement from the Government of Andhra Pradesh is received it will be offered

DCIT, Circle-1(1), Vijayawada vs. Transmission Corporation of Andhra Pradesh Limited, Vijayawada

In the results, appeals filed by the revenue in ITA Nos

ITA 339/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23) Dcit – Circle – 1(1) Vs. Transmission Corporation Of Cr Buildings, M.G. Road Andhra Pradesh Limited Vijayawada – 520002 48-12-4/1, Gunadala Andhra Pradesh Vijayawada – 520004 Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) सी.ओ सं. / C.O. Nos. 30, 31, 32, 33, 34 & 35/Viz/2025 [आयकर अपीलसं.से उत्पन्न/I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23)] Transmission Corporation Of Vs. Dcit – Circle – 1(1) Andhra Pradesh Limited Cr Buildings, M.G. Road 48-12-4/1, Gunadala Vijayawada – 520002 Vijayawada – 520004 Andhra Pradesh Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri M. Chandramouleswara Rao, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

considered the above submissions and held that the expenditure incurred by the assessee towards restoration of transmission infrastructure damaged during the HUDHUD cyclone as revenue expenditure allowable under provisions of section 37(1) of the Act. He therefore pleaded that order of the Ld. CIT(A) be upheld ... Andhra Pradesh Limited expenditure, the Company has charged it to the Profit & Loss Account during the impugned assessment year and claimed as the revenue expenditure. It was also submitted by the Ld.AR that as and when the reimbursement from the Government of Andhra Pradesh is received it will be offered

DCIT, Circle-1(1), Vijayawada vs. Transmission Corporation of Andhra Pradesh Limited, Vijayawada

In the results, appeals filed by the revenue in ITA Nos

ITA 335/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23) Dcit – Circle – 1(1) Vs. Transmission Corporation Of Cr Buildings, M.G. Road Andhra Pradesh Limited Vijayawada – 520002 48-12-4/1, Gunadala Andhra Pradesh Vijayawada – 520004 Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) सी.ओ सं. / C.O. Nos. 30, 31, 32, 33, 34 & 35/Viz/2025 [आयकर अपीलसं.से उत्पन्न/I.T.A.Nos.335, 339, 340, 341, 342 & 343/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2015-16, 2017-18, 2018-19, 2020-21, 2021-22 & 2022-23)] Transmission Corporation Of Vs. Dcit – Circle – 1(1) Andhra Pradesh Limited Cr Buildings, M.G. Road 48-12-4/1, Gunadala Vijayawada – 520002 Vijayawada – 520004 Andhra Pradesh Andhra Pradesh [Pan:Aabct0088P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri M. Chandramouleswara Rao, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

considered the above submissions and held that the expenditure incurred by the assessee towards restoration of transmission infrastructure damaged during the HUDHUD cyclone as revenue expenditure allowable under provisions of section 37(1) of the Act. He therefore pleaded that order of the Ld. CIT(A) be upheld ... Andhra Pradesh Limited expenditure, the Company has charged it to the Profit & Loss Account during the impugned assessment year and claimed as the revenue expenditure. It was also submitted by the Ld.AR that as and when the reimbursement from the Government of Andhra Pradesh is received it will be offered

Teejay India Private Limited, Visakhapatnam vs. Deputy Commissioner of Income Tax, Circle-5(1), Visakhapatnam

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

ITA 340/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.340/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2020-21) & S.A. No. 15/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2020-21) Teejay India Private Limited, Vs. Deputy Commissioner Of Plot No. 15, Brandix, Apsez, Income Tax, Pudimadaka Road, Atchutapuram Circle-5(1), Mandal, Visakhapatnam-530011. Visakhapatnam. Pan: Aaaco9452H (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Sri Darpan Kirpalani, AdvocateFor Respondent: Dr. Satyasai Rath, CIT(DR)
Section 142(1)Section 143(2)Section 143(3)Section 144C(5)Section 92C

that same as an apportionment of prior period expenditure and further that the same is disallowable expenditure since there is no concept of deferred revenue expenditure in IT Act and all that the expenses must be allowed in the year in which it is incurred. 4.2. Failing to appreciate that ... that it is one time lumpsum payment and a prior period expenditure which cannot be apportioned during the impugned assessment year as revenue expenditure. The assessee has claimed proportionate share of amortization of leasehold charges amounting to Rs. 23,47,826/- for the relevant assessment year. There are various judicial

Unimed Technologies Limited, Panchmahal vs. The ACIT, Circle-2(1)(1), Vadodara

ITA 623/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Jul 2025AY 2016-17

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2016-17 Unimed Technologies Limited Acit, Cir.2(1)(1) Survey No.22 & 22, Vs. Vadodara. Baska, Ujeti Halol Panchmahal Pan : Aaace 4022 B Asstt.Year : 2016-17 Acit, Cir.2(1)(1) Unimed Technologies Limited Vadodara. Vs. Survey No.22 & 22, Baska, Ujeti Halol Panchmahal Pan : Aaace 4022 B (Applicant) (Responent) : Shri Bandish Soparkar, Ar Assessee By : Shri Sher Singh, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 17/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 24/07/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Sher Singh, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 234BSection 250Section 271(1)(b)Section 271(1)(c)Section 36(1)(iii)Section 37(1)

that the borrowings were used for repayment of trade liabilities and for regular business requirements, and hence, the entire interest expenditure was allowable as revenue expenditure under section 36(1)(iii) of the Act. Additionally, the CIT(A) directed the Assessing Officer to rectify the computation of tax by granting ... said amount had been debited by the assessee under the head “software expenses” in the profit and loss account and treated it as revenue expenditure. However, on examination of the details from the copies of the bills, the AO noted that the expenditure comprised items such as rugged computers, barcode