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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

Assistant Commissioner of Income Tax Ltu Circle 1 Chennai, Chennai vs. E I D Parry India Limited, Chennai

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

ITA 3251/CHNY/2024[2012-13]Status: DisposedITAT Chennai21 Apr 2025AY 2012-13

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(1)Section 143(2)Section 250Section 92BSection 92C

which the capital expenditure is ₹.17,84,000/- (being 100%) and the revenue expenditure is ₹.4,47,08,500 (being 100%). Since, vide letter dated 10.07.2012, the DSIR has certified the capital expenditure of ₹.17,84,000/- and revenue expenditure of ₹.3,67,27,000/- as eligible for weighted deduction ... under section 35(2AB) of the Act, the Assessing Officer disallowed the excess claim of weighted deduction on revenue expenditure for ₹.79,81,500/-. Aggrieved by the order of the Assessing Officer, the assessee carried the matter in appeal before the CIT(A). The CIT(A), by following various decisions

Deputy Commissioner of Income Tax, Madurai vs. Ramco Cements Limited, Rajapalayam

In the result, both the appeals filed by the Revenue are dismissed

ITA 3234/CHNY/2024[2011-12]Status: DisposedITAT Chennai17 Apr 2025AY 2011-12

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.3234 & 3059/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12 & 2015-16 The Deputy/Assistant Commissioner Vs. Ramco Cements Limited, Of Income Tax, Ramamandiram, Rajapalayam, Corporate Circle 2, Virudhunagar District – 626 117, Madurai. Tamil Nadu. [Pan:Aabcm8375L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Shivanand K Kalakeri, Cit ""थ" की ओर से/Respondent By : Shri S. Muralidhar, F.C.A. & Shri J. Prabhakar, F.C.A. सुनवाई की तारीख/ Date Of Hearing : 09.04.2025 घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Revenue Are Directed Against Separate Orders Dated 17.10.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2011-12 & Order Dated 27.09.2024 Passed By The Ld. Cit(A) – 16, Chennai For The Assessment Year 2015-16. 2. Since Issues Raised In Both The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

For Appellant: Shri Shivanand K Kalakeri, CiTFor Respondent: Shri S. Muralidhar, F.C.A. &

Ground No. 6 raised by the Appellant-Revenue in challenging the action of the ld. CIT(A) in treating the railway siding expenses as revenue expenditure. 12. The assessee company claimed ₹.24,57,02,256/- towards cost of railway sidings as revenue expenditure in the profit and loss account. However ... granting depreciation @ 10%, the Assessing Officer rejected the claim of the assessee and disallowed the same to be written off as revenue expenditure and added to the total income of the assessee. In appeal, by following the decision of the ITAT in assessee’s own case

Assistant Commissioner of Income Tax, Madurai vs. Ramco Cements Limited, Rajapayalam

In the result, both the appeals filed by the Revenue are dismissed

ITA 3059/CHNY/2024[2015-16]Status: DisposedITAT Chennai17 Apr 2025AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.3234 & 3059/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12 & 2015-16 The Deputy/Assistant Commissioner Vs. Ramco Cements Limited, Of Income Tax, Ramamandiram, Rajapalayam, Corporate Circle 2, Virudhunagar District – 626 117, Madurai. Tamil Nadu. [Pan:Aabcm8375L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Shivanand K Kalakeri, Cit ""थ" की ओर से/Respondent By : Shri S. Muralidhar, F.C.A. & Shri J. Prabhakar, F.C.A. सुनवाई की तारीख/ Date Of Hearing : 09.04.2025 घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Revenue Are Directed Against Separate Orders Dated 17.10.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2011-12 & Order Dated 27.09.2024 Passed By The Ld. Cit(A) – 16, Chennai For The Assessment Year 2015-16. 2. Since Issues Raised In Both The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

For Appellant: Shri Shivanand K Kalakeri, CiTFor Respondent: Shri S. Muralidhar, F.C.A. &

Ground No. 6 raised by the Appellant-Revenue in challenging the action of the ld. CIT(A) in treating the railway siding expenses as revenue expenditure. 12. The assessee company claimed ₹.24,57,02,256/- towards cost of railway sidings as revenue expenditure in the profit and loss account. However ... granting depreciation @ 10%, the Assessing Officer rejected the claim of the assessee and disallowed the same to be written off as revenue expenditure and added to the total income of the assessee. In appeal, by following the decision of the ITAT in assessee’s own case

Assistant Commissioner of Income Tax Ltu Circle 1, Nungambakkam Chennai vs. Sify Technologies Limited, Taramani Chennai

In the result, all the appeals filed by the Revenue are dismissed

ITA 2889/CHNY/2024[2012-13]Status: DisposedITAT Chennai17 Apr 2025AY 2012-13

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos. 1458, 1950 & 2889/Chny/2024 िनधा"रण वष"/Assessment Years: 2020-21, 2017-18 & 2012-13 The Deputy Commissioner Of Vs. M/S. Sify Technologies Limited, Income Tax/Acit, Ii Floor, Tidel Park No. 4, Ttt1 Large Taxpayer Unit Circle 1, Taramani S.O., Taramani, Chennai. Chennai 600 113. [Pan:Aaacs9032R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Shivanand K Kalakeri, Cit ""थ" की ओर से/Respondent By : Shri S.P. Chidambaram, Advocate सुनवाई की तारीख/ Date Of Hearing : 13.03.2025 घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Three Appeals Filed By The Revenue Are Directed Against Separate Orders Dated 19.02.2024, 07.08.2023 & 08.08.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2020-21, 2017-18 & 2012-13. 2. Since Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed

For Appellant: Shri Shivanand K Kalakeri, CITFor Respondent: Shri S.P. Chidambaram, Advocate

contingent liability until and unless the eligible employee exercises the option and therefore, the expenditure claimed by the assessee cannot be allowed as revenue expenditure. Accordingly, the Assessing Officer disallowed the claim of the assessee and added back to the returned income. On appeal, the ld. CIT(A), by following

Asst Commissioner of Income Tax Circle Ltu 1 Chennai, Nungambakkam vs. Sify Technologies Limited, Chennai

In the result, all the appeals filed by the Revenue are dismissed

ITA 1950/CHNY/2024[2017-18]Status: DisposedITAT Chennai17 Apr 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos. 1458, 1950 & 2889/Chny/2024 िनधा"रण वष"/Assessment Years: 2020-21, 2017-18 & 2012-13 The Deputy Commissioner Of Vs. M/S. Sify Technologies Limited, Income Tax/Acit, Ii Floor, Tidel Park No. 4, Ttt1 Large Taxpayer Unit Circle 1, Taramani S.O., Taramani, Chennai. Chennai 600 113. [Pan:Aaacs9032R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Shivanand K Kalakeri, Cit ""थ" की ओर से/Respondent By : Shri S.P. Chidambaram, Advocate सुनवाई की तारीख/ Date Of Hearing : 13.03.2025 घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Three Appeals Filed By The Revenue Are Directed Against Separate Orders Dated 19.02.2024, 07.08.2023 & 08.08.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2020-21, 2017-18 & 2012-13. 2. Since Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed

For Appellant: Shri Shivanand K Kalakeri, CITFor Respondent: Shri S.P. Chidambaram, Advocate

contingent liability until and unless the eligible employee exercises the option and therefore, the expenditure claimed by the assessee cannot be allowed as revenue expenditure. Accordingly, the Assessing Officer disallowed the claim of the assessee and added back to the returned income. On appeal, the ld. CIT(A), by following

Deputy Commissioner of Income Tax, Chennai vs. Sify Technologies Limited, Chennai

In the result, all the appeals filed by the Revenue are dismissed

ITA 1458/CHNY/2024[2020-21]Status: DisposedITAT Chennai17 Apr 2025AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos. 1458, 1950 & 2889/Chny/2024 िनधा"रण वष"/Assessment Years: 2020-21, 2017-18 & 2012-13 The Deputy Commissioner Of Vs. M/S. Sify Technologies Limited, Income Tax/Acit, Ii Floor, Tidel Park No. 4, Ttt1 Large Taxpayer Unit Circle 1, Taramani S.O., Taramani, Chennai. Chennai 600 113. [Pan:Aaacs9032R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Shivanand K Kalakeri, Cit ""थ" की ओर से/Respondent By : Shri S.P. Chidambaram, Advocate सुनवाई की तारीख/ Date Of Hearing : 13.03.2025 घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Three Appeals Filed By The Revenue Are Directed Against Separate Orders Dated 19.02.2024, 07.08.2023 & 08.08.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2020-21, 2017-18 & 2012-13. 2. Since Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed

For Appellant: Shri Shivanand K Kalakeri, CITFor Respondent: Shri S.P. Chidambaram, Advocate

contingent liability until and unless the eligible employee exercises the option and therefore, the expenditure claimed by the assessee cannot be allowed as revenue expenditure. Accordingly, the Assessing Officer disallowed the claim of the assessee and added back to the returned income. On appeal, the ld. CIT(A), by following

Skm Egg Products Export Ltd, Erode vs. DCIT, Central Circle Salem, Salem

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

ITA 2933/CHNY/2024[2013-14]Status: DisposedITAT Chennai07 Apr 2025AY 2013-14

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 2933/Chny/2024 िनधा"रण वष" / Assessment Year: 2013-14 Skm Egg Products Export The Deputy Commissioner (India) Ltd., V. Of Income Tax, No.133/1, Gandhiji Street, Central Circle, Erode – 638 001. Salem. [Pan:Aaccs 7106G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent By : Shri Shivanand K Kalakeri, Cit सुनवाई क" तार"ख/Date Of Hearing : 12.03.2025 घोषणा क" तार"ख/Date Of Pronouncement : 07.04.2025 आदेश /O R D E R

For Appellant: Shri G. Baskar, AdvocateFor Respondent: Shri Shivanand K Kalakeri, CIT
Section 143(2)Section 143(3)Section 37

Chennai. 4. Before the ld.CIT(A), the assessee submitted that there is no dispute that said expenses are in the nature of revenue expenditure. The assessee also submitted that the expenditure has been incurred at Russia under 15 heads of expenses from the financial year ... Rs.3,40,02,145/-. Further, the assessee explained that these expenses were incurred for the establishment of Russian branch in the nature of revenue expenditure. Further, the assessee also explained that similar issue of the assessee’s own case came up for consideration for the assessment year 2011-12 concerning