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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

DCIT., Circle 8(1), Hyderabad vs. East India Petroleum Limited, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 1087/HYD/2024[2018-19]Status: DisposedITAT Hyderabad06 Feb 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri K.Narsimha Charyआ.अपी.सं /Ita No.1087/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19) Deputy Commissioner Of Vs. East India Petroleum Income Tax Limited Circle-8(1)(Incharge) Hyderabad Hyderabad [Pan : Aaace4494K] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri H.Srinivasulu, Ar रधजस् व द्वधरध/Revenue By: Ms.M.Narmada, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 16/01/2025 घोर्णध की तधरीख/Date Of 06/02/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Revenue Is Directed Against Order Dated 19.08.2024 Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”], National Faceless Appeal Centre (Nfac), Delhi, Pertaining To A.Y.2018-19. 2. The Brief Facts Of The Case Are That The Assessee, Engaged In The Business Of Providing Terminalling Services To Oil Marketing Companies For Storage Of Bulk Liquid Products Including Fuels Like High Speed Diesel, Motor Spirit, Petroleum

For Appellant: Shri H.Srinivasulu, ARFor Respondent: Ms.M.Narmada, CIT-DR
Section 32

amalgamation, the same loan liability has been taken over by the assessee and the assessee company has treated interest as revenue expenditure. Therefore, observed that, if this claim of interest expenditure is allowed, it would amount to allowing assessee company payment of interest on money borrowed for buying ... account. On amalgamation, the same loan liability has been taken over by the assessee and interest paid on said loan has been treated as revenue expenditure. The Assessing Officer further observed that, if interest claim is allowed, it will tantamount to allowing assessee company, payment of interest on money borrowed

Income Tax Officer, Ward-1, Khammam vs. Varalakhsmi Constructions, Khammam

In the result, both the appeal filed by the revenue are dismissed

ITA 304/HYD/2024[2016-17]Status: DisposedITAT Hyderabad04 Feb 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.303 & 304/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15 & 2016-17) Income Tax Officer Vs. Varalakshmi Ward-1 Constructions Khammam Khammam Pan:Aagfv0744C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 23/01/2025 घोषणा की तारीख/Pronouncement: 04/02/2025 आदेश/Order Per Vijay Pal Raothese Two Appeals Filed By The Revenue Are Directed Against The Separate Orders Of The Learned Cit (A) Nfac Delhi Both Dated 22/01/2024 For The A.Ys 2014-15 & 2016-17 Respectively. The Revenue Has Raised Identical Grounds Of Appeal For These A.Ys. The Grounds Raised By The Revenue For The A.Y 2014-15 Are As Under:

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B Bala Krishna, CIT(DR)
Section 144Section 148Section 69A

expenditure. In the absence of books and vouchers, one cannot specifically conclude that the amounts withdrawn were indeed deployed and were incurred towards revenue expenditure and got debited to P&L acct. It is also seen that the withdrawals were actually more than the entire turnover of the appellant firm ... business expenditure. The CIT(A) has rightly pointed out that the amounts withdrawn cannot be presumed to have been deployed and incurred towards revenue expenditure and got debited to the Profit & Loss Account. Where there is estimation of business income, disallowance and consequential addition of revenue expenditure is not sustainable

Income Tax Officer, Ward 1, Khammam vs. Varalakshmi Constructions, Khammam

In the result, both the appeal filed by the revenue are dismissed

ITA 303/HYD/2024[2014-15]Status: DisposedITAT Hyderabad04 Feb 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.303 & 304/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15 & 2016-17) Income Tax Officer Vs. Varalakshmi Ward-1 Constructions Khammam Khammam Pan:Aagfv0744C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 23/01/2025 घोषणा की तारीख/Pronouncement: 04/02/2025 आदेश/Order Per Vijay Pal Raothese Two Appeals Filed By The Revenue Are Directed Against The Separate Orders Of The Learned Cit (A) Nfac Delhi Both Dated 22/01/2024 For The A.Ys 2014-15 & 2016-17 Respectively. The Revenue Has Raised Identical Grounds Of Appeal For These A.Ys. The Grounds Raised By The Revenue For The A.Y 2014-15 Are As Under:

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B Bala Krishna, CIT(DR)
Section 144Section 148Section 69A

expenditure. In the absence of books and vouchers, one cannot specifically conclude that the amounts withdrawn were indeed deployed and were incurred towards revenue expenditure and got debited to P&L acct. It is also seen that the withdrawals were actually more than the entire turnover of the appellant firm ... business expenditure. The CIT(A) has rightly pointed out that the amounts withdrawn cannot be presumed to have been deployed and incurred towards revenue expenditure and got debited to the Profit & Loss Account. Where there is estimation of business income, disallowance and consequential addition of revenue expenditure is not sustainable