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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

Income Tax Officer, Corporate Ward -3(1), Chennai vs. Ttk Healthcare Limited, Chennai

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

ITA 2254/CHNY/2024[2015-16]Status: DisposedITAT Chennai27 Nov 2024AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.2254/Chny/2024 िनधा"रण वष"/Assessment Year: 2015-16 The Income Tax Officer, Vs. Ttk Healthcare Limited, Corporate Ward 3(1), No. 6, Cathedral Road, Chennai. Gopalapuram, Chennai 600 086. [Pan:Aabct3312J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri C. Murugesan, Addl. Cit ""थ" की ओर से/Respondent By : Shri Vikram Vijayaraghavan, Advocate (Virtual) सुनवाई की तारीख/ Date Of Hearing : 26.11.2024 घोषणा की तारीख /Date Of Pronouncement : 27.11.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Revenue Is Directed Against The Order Dated 27.06.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2015-16. 2. We Note That The Return Of Income Filed By The Assessee Was Selected For Scrutiny & Assessment Order Was Passed Assessing Income Of ₹.35,75,45,407/-. The Assessing Officer Reopened The 2

For Appellant: Shri C. Murugesan, Addl. CITFor Respondent: Shri Vikram Vijayaraghavan, Advocate
Section 147Section 14A

that the issue is squarely covered in favour of the assessee by the order of the Tribunal, wherein, the logo charges was treated as revenue expenditure. He brought on record the decision of the Tribunal vide order dated 08.08.2024 for the assessment years ... Techno Services Limited [TTK Healthcare Private Ltd.) for AY 2020-21 also the Tribunal held that the logo charges incurred by the assessee is revenue expenditure by following the order of the Tribunal vide order dated 08.08.2024 in ITA Nos. 1459 to 1461/Chny/2024, wherein, the Tribunal held as under

Assistant Commissioner of Income Tax, Circle-1, Tirunelveli vs. Vvd and Sons Private Limited, Tuticorin

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

ITA 1792/CHNY/2024[2017-18]Status: DisposedITAT Chennai26 Nov 2024AY 2017-18

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1792/Chny/2024 निर्धारण वर्ष/Assessment Year: 2017-18 The Assistant Commissioner Of Income Tax, Circle - 1, Tirunelveli. (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By Vvd & Sons Private Vs. Limited, No.182, Palayamkottai Road, Tuticorin – 628 003. Pan: Aaacv 8438J (प्रत्यर्थी/Respondent) Shri Shiva Srinivas, Addl.Cit Shri S. Sridhar, Advocate सुनवाई की तारीख/Date Of Hearing : 21.11.2024 घोषणा की तारीख/Date Of Pronouncement : 26.11.2024 आदेश /O R Der Per S.R. Raghunatha: This Appeal Filed By The Revenue Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), Chennai 19, Dated 30.04.2024 & Pertains To

Section 4Section 801Section 801ASection 80I

further contended that while computing profit of the business of industrial undertakings under Section 80IA of the Act, revenue receipts should be adjusted against revenue expenditure of like nature. In the present case of the Appellant company, the revenue receipt in the form of interest on delayed payments from TNEB

Asian Hotels (North) Limited, New Delhi vs. Pr, CIT, Delhi-1, New Delhi

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

ITA 654/DEL/2021[2016-17]Status: DisposedITAT Delhi26 Nov 2024AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek, Judicialmember M/S. Asian Hotels (North) Limited, Vs. Pr.Cit, 1A, Hotel Hyatt Regency, Delhi – 1. Bhikaji Cama Place, New Delhi – 110 066. (Pan: Aaaca0125H) (Appellant) (Respondent) Assessee By : Shri Abhishek Jain, Ca Revenue By : Shri Javed Akhtar, Cit Dr Date Of Hearing : 17.09.2024 Date Of Order : 26.11.2024 O R D E R Per S. Rifaur Rahman, Am : 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Principal Commissioner Of Income-Tax, Delhi-1 (Hereinafter Referred To ‘Ld. Pcit’) Dated 31.03.2021 For Assessment Year 2016-17. 2. Brief Facts Of The Case Are, Assessee Filed Its Return Of Income On 29.09.2016 Declaring A Loss Of Rs.32,48,76,393/-. The Case Was Selected For Complete Scrutiny Under Cass. The Assessment Was Completed Under Section 143 (3)

For Appellant: Shri Abhishek Jain, CAFor Respondent: Shri Javed Akhtar, CIT DR
Section 143Section 143(3)Section 41(1)Section 438

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 his submission that one has to keep in mind the distinction between "lack of inquiry" and "inadequate