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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

Linguanext Technologies Private Limited, Pune vs. ITO Ward 14(3), Pune

In the result, the appeal of the assessee is partly allowed

ITA 2535/PUN/2024[2014-15]Status: DisposedITAT Pune20 Mar 2025AY 2014-15

Bench: Shri Manish Borad & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.2535/Pun/2024 िनधा"रण वष" / Assessment Year : 2014-15 Linguanext Technologies Vs. Ito, Ward-14(3), Pune. Private Limited, 401, Galore Tech Park, Behind Maratha Mandir, Bavdhan, Pune- 411021. Pan : Aabcl7322G Appellant Respondent Assessee By : Shri Kishore Phadke Revenue By : Shri Manoj Tripathi Date Of Hearing : 17.03.2025 Date Of Pronouncement : 20.03.2025 आदेश / Order Per Manish Borad, Am: This Appeal Filed At The Instance Of Assessee Is Directed Against The Order Of Ld. Addl/Jcit(A)-6, Chennai [‘Ld. Cit(A)’] Dated 19.11.2024 Which Is Arising Out Of The Assessment Order U/S 143(3) Of The Act For Assessment Year 2014-15 Framed On 29.12.2016 By The Ito, Ward-14(3), Pune. 2. Brief Facts Of The Case Are That The Assessee Is A Private Limited Company & Engaged In Software Development Business. Return

For Appellant: Shri Kishore PhadkeFor Respondent: Shri Manoj Tripathi
Section 143(2)Section 143(3)Section 14ASection 37(1)

with referring to the decisions in support of the claim that the expenditure incurred towards patent drafting and translation expenses for software development are revenue expenditure. So far 3 as disallowance u/s 14A of the Act is concerned, it is stated that even though Ld. Assessing Officer had failed ... been capitalized in the financial statement considering the non- satisfaction of recognition and measurement criteria, the alleged amount has been claimed as ‘revenue expenditure’. We also observe that the alleged expenditure incurred has not created new asset during the year for which it is claimed. 9. We therefore considering

Strides Pharma Science Limited, Mumbai vs. Income Tax Officer, 15(3)(2), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 5721/MUM/2024[2020-21]Status: DisposedITAT Mumbai20 Mar 2025AY 2020-21

Bench: Shri Amit Shukla & Smt. Renu Jauhriआयकर अपील सं./Ita No.5721/Mum/2024 (निर्धारण वर्ष / Assessment Year :2020-21) Strides Pharma Science Limited V/S. Ito 15(3)(2), बनाम Aayakar Bhavan, New 201, Devavrata, Sector-17, Marine Lines, Mumbai-400020 Vashi, Navi Mumbai, Maharashtra-400703 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Blrs03808A .. Appellant/अपीलार्थी Respondent/प्रतिवादी निर्धारिती की ओर से /Assessee By: Shri Nishit Gandhi राजस्व की ओर से /Revenue By: Mr. R. A. Dhyani सुनवाई की तारीख / Date Of Hearing 16.01.2025 20.03.2025 घोषणा की तारीख/Date Of Pronouncement आदेश / Order Per Renu Jauhri [A.M.] :- This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Mumbai/National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”] Dated 06.09.2024 Passed U/S.250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “Act”] For

For Appellant: Shri Nishit GandhiFor Respondent: Mr. R. A. Dhyani
Section 143(3)Section 144Section 14ASection 250Section 35Section 37(1)

without appreciating the fact that ESOP expenses are not capital expenditure or a contingent liability but an ascertained revenue expenditure allowed under section 37(1) of the Act. 2.3 Further, the NFAC erred in not following the judicial discipline by disregarding the decision issued by the honorable High Court ... does not tantamount to the disallowance of actual expenses. 3.3 The learned AO and CIT(A) ought to have appreciated the fact that the revenue expenditure which is not approved by DSIR can be claimed as normal business expenditure and not to be disallowed under section

ACIT, New Delhi vs. M/S. Bbc World India Pvt. Ltd., New Delhi

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

ITA 3489/DEL/2016[2008-09]Status: DisposedITAT Delhi12 Mar 2025AY 2008-09

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