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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

Renu Electronics Pvt. Ltd., Pune vs. ACIT, Circle 5, Pune

In the result, appeal filed by the assessee is allowed

ITA 132/PUN/2024[2017-18]Status: DisposedITAT Pune20 Sept 2024AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.132/Pun/2024 िनधा"रण वष" / Assessment Year: 2017-18 Renu Electronics Pvt. Ltd., Vs. Acit, Circle-5, Pune. S.No.2/6, Near Baner Telephone Exchange, Baner, Pune- 411045. Pan : Aaacr8741G Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Ajay Kumar Keshari Date Of Hearing : 25.06.2024 Date Of Pronouncement : 20.09.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.12.2023 Passed By Ld Cit(A)/Nfac For The Assessment Year 2017-18. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1] The Learned Cit(A) Erred In Confirming The Disallowance Of Weighted Deduction Amounting To Rs.9,25,79,494/- U/S 35(2Ab) Of The Act. 2] The Learned Cit(A) Erred In Holding That The Assessee Company Was Not Entitled To Claim Weighted Deduction U/S 35(2Ab) Since Form No. 3Cla Was Filed By The Assessee Beyond The Due Date Specified U/S 139(1) Of The Act.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Ajay Kumar Keshari
Section 139(1)Section 143(2)Section 35Section 37(1)

above grounds, the assessee submits that in case, the claim of weighted deduction u/s 35(2AB) is denied, in that event, the revenue expenditure incurred by the assessee ought to have been allowed as a deduction u/s 37(1) of the Act. 10] The appellant craves leave to add, alter ... Income Tax Rules, 1962. It was noticed by the Assessing Officer that the DSIR has certified the amount of Rs.4,33,74,000/- as ‘revenue expenditure’ and Rs.3,00,000/- as ‘capital expenditure’ vide its certificate dated 30.11.2018. However, as mentioned in the table above, the assessee company has claimed