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“Section 37(1)”

Section References (mined)Section 37Section 37(1)4,308 judgments

The decision most relied on for Section 37(1) is CIT v. Reliance Utilities & Power Ltd. (313 ITR 340), cited in 2,118 judgments on BharatTax.

Leading authorities on Section 37(1)

CIT v. Reliance Utilities & Power Ltd.
313 ITR 340 · 2009 · High Court
2,118
citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

Goetze (India) Ltd. v. CIT
284 ITR 323 · 2006 · Supreme Court
1,842
citing judgments

An assessee cannot raise a new claim or a claim not made in the original or revised return of income for the first time directly before the Assessing Officer during assessment proceedings.

Maxopp Investment Ltd. v. CIT
402 ITR 640 · 2018 · Supreme Court
1,596
citing judgments

Disallowance under Section 14A is not automatic and requires the Assessing Officer to record satisfaction before applying Rule 8D. Only investments yielding exempt income are considered for disallowance, irrespective of their strategic nature.

Cheminvest Ltd. v. CIT
378 ITR 33 · 2015 · High Court
1,569
citing judgments

A disallowance under Section 14A of the Income-tax Act, 1961, for expenditure incurred in relation to exempt income cannot be made if the assessee has not earned any exempt income during the relevant previous year.

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. HDFC Bank Ltd.
366 ITR 505 · 2014 · High Court
1,261
citing judgments

When an assessee possesses interest-free funds sufficient to cover investments yielding tax-free income, it is presumed that such investments were made from these interest-free funds, precluding disallowance of interest expenditure under Section 14A.

Godrej & Boyce Mfg. Co. Ltd. v. DCIT
328 ITR 81 · 2010 · High Court
1,183
citing judgments

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

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.

Judgments citing Section 37(1)

Naresh Kumar, Shanti Nagar, Model Town, Panipat, Haryana, India vs. Assessing Officer, Ward No. One, Panipat Haryana, India

In the result, the appeal of the assessee in ITA No

ITA 3656/DEL/2025[2023-24]Status: DisposedITAT Delhi30 Dec 2025AY 2023-24

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 143(1)Section 282

plea that the belated deposit of employees contributions to PF/ESIC governed under Section 36(1)(va) is also simultaneously amenable to deduction under Section 37(1) of the Act. In terms of the provision, Section 37(1) permits deduction of expenditure which is not in the nature of expenditure prescribed ... personal expenses of the assessee. Thus, in view of such mandate of law, the deduction of expenditure under the general clause of Section 37(1) would not extend to expenditure specially covered within the ambit of Section 36(1)(va) of the Act. The Hon'ble Supreme Court

Naresh Kumar, Shanti Nagar, Model Town, Panipat, Haryana, India vs. Assessing Officer, Ward One, Panipat, Haryana, India

In the result, the appeal of the assessee in ITA No

ITA 3654/DEL/2025[2021-22]Status: DisposedITAT Delhi30 Dec 2025AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 143(1)Section 282

plea that the belated deposit of employees contributions to PF/ESIC governed under Section 36(1)(va) is also simultaneously amenable to deduction under Section 37(1) of the Act. In terms of the provision, Section 37(1) permits deduction of expenditure which is not in the nature of expenditure prescribed ... personal expenses of the assessee. Thus, in view of such mandate of law, the deduction of expenditure under the general clause of Section 37(1) would not extend to expenditure specially covered within the ambit of Section 36(1)(va) of the Act. The Hon'ble Supreme Court

Westcourt Hospitality Pvt Ltd, New Delhi vs. DCIT, Circle-25(1), Delhi

In the result appeal of the assessee is allowed

ITA 3351/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year: 2018-19] Acit, Circle 25(1), Room Vs M/S. Westcourt Hospitality No. 192A, Cr Building, Pvt. Ltd. Ip Estate New-Delhi. 4391, B-5 & 6, Vasant Kunj, 110002 New Delhi-110070. Pan-Aaacw8734G Appellant Respondent [Assessment Year: 2018-19] M/S. Westcourt Hospitality Vs Acit, Circle 25(1),Room Pvt. Ltd. No. 192A, Cr Building, Ip 4391, B-5 & 6, Vasant Estate New-Delhi. 110002 Kunj, New Delhi-110070. Pan-Aaacw8734G Appellant Respondent

Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

into mind the concept behind section 57(iii). 7. Your lordships will appreciate that there is clear cut distinction between the scope of section 37(1) and the scope of section 57(iii), in as much as the former talks about the expenses incurred 'for the purposes of the business ... about the expenses incurred 'wholly and exclusively for the purpose of making or earning such income'. 8. Your lordships will also appreciate that section 37(1) does not mandate that the expenses incurred for the purposes of business must yield some income to the assessee. For this proposition, the reliance

Assistant Commissioner of Income Tax, Circle-25(1), New Delhi vs. Westcourt Hospitality Private Limited, New Delhi

In the result appeal of the assessee is allowed

ITA 3294/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year: 2018-19] Acit, Circle 25(1), Room Vs M/S. Westcourt Hospitality No. 192A, Cr Building, Pvt. Ltd. Ip Estate New-Delhi. 4391, B-5 & 6, Vasant Kunj, 110002 New Delhi-110070. Pan-Aaacw8734G Appellant Respondent [Assessment Year: 2018-19] M/S. Westcourt Hospitality Vs Acit, Circle 25(1),Room Pvt. Ltd. No. 192A, Cr Building, Ip 4391, B-5 & 6, Vasant Estate New-Delhi. 110002 Kunj, New Delhi-110070. Pan-Aaacw8734G Appellant Respondent

Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

into mind the concept behind section 57(iii). 7. Your lordships will appreciate that there is clear cut distinction between the scope of section 37(1) and the scope of section 57(iii), in as much as the former talks about the expenses incurred 'for the purposes of the business ... about the expenses incurred 'wholly and exclusively for the purpose of making or earning such income'. 8. Your lordships will also appreciate that section 37(1) does not mandate that the expenses incurred for the purposes of business must yield some income to the assessee. For this proposition, the reliance

Income Tax Officer, Rohtak vs. Pankaj Jain, Rohtak

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

ITA 2295/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Dec 2025AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmaincome Tax Officer, Vs. Pankaj Jain, Rohtak. 123/34, Vishwakarma Kathmandi, Rohtak – 124 001 (Haryana). (Pan : Azupj6345A) (Appellant) (Respondent) Assessee By : Shri Shri Naveen Gupta, Advocate Shri Nakul Gupta, Advocate Revenue By : Shri Ajay Kumar Arora,Sr. Dr Date Of Hearing : 06.11.2025 Date Of Order : 30.12.2025 Order Per S. Rifaur Rahman: 1. The Assessee 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 04.02.2025 For The Assessment Year 2018-19 Raising Following Grounds Of Appeal :- “1. The Learned Cit(A) Has Erred In Law & On Facts In Not Upholding The Validity Of The Notice Issued Under Section 148 Of The Income Tax Act, 1961 (The Act) Without The Proper & Mandatory Compliance With The Provisions Of Section 148A(B). 2. The Learned Cit(A) Has Further Erred In Law & On Facts By Failing To Consider That The Then Ao Has Given Notice U/S 148A(B) To Assessee On 31.03.2022

For Appellant: Shri Shri Naveen Gupta, AdvocateFor Respondent: Shri Ajay Kumar Arora,Sr. DR
Section 133(6)Section 142(1)Section 143Section 147Section 148Section 148ASection 151Section 151ASection 292BSection 37(1)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI ANUBHAV SHARMA

Haryana Urban Development Authority, Panchkula, Haryana vs. Principal Commissioner of Income Tax, Panchkula, Haryana

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

ITA 668/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh29 Dec 2025AY 2021-22
For Respondent: Ms. Rattan Kaur & Shri A.K. Jindal, C.A's
Section 263Section 37Section 37(1)Section 43B

clearly penal in nature. The steep hike is intended to deter continued default, thereby bringing it within the ambit of the Explanation to Section 37(1), which disallows expenditure incurred for any purpose that is an offence or prohibited by law (penalty). The payment of interest after 3 months loses ... error. The AO simply accepted the nomenclature of "interest" without applying his mind to the definition u/s 2(28A) or the Explanation to Section 37(1). 13. In light of the specific provisions of the Haryana VAT Act providing for a penal rate of 3%, the PCIT was justified

M/S.U.S.Reality Private Limited, Mumbai vs. Deputy Commissioner of Income Tax-10(3), Mumbai

In the result the appeal is allowed for statistical purposes

ITA 1959/MUM/2018[2010-11]Status: DisposedITAT Mumbai29 Dec 2025AY 2010-11

Bench: Shri Sandeep Singh Karhail & Shri Makarand Vasant Mahadeokar

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144Section 145(3)Section 37(1)Section 68

entry was merely a book entry passed on ill advice. The Assessing Officer held that the assessee failed to discharge the onus under section 37(1) to prove that the expenditure was actually incurred for business purposes, noted absence of supporting evidence and the assessee's own admission that

Dy. Commissioner of Income Tax, Central Circle-3(3), Mumbai vs. Kalpataru Projects International Limited, Gujarat

In the result, the appeals by the assessee for the assessment years

ITA 6112/MUM/2025[2013-14]Status: DisposedITAT Mumbai24 Dec 2025AY 2013-14

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT-DR
Section 147Section 148Section 250Section 37(1)

learned Authorised Representative (“learned AR”), at the outset, wishes to argue the ground raised on merits pertaining to the disallowance made under section 37(1) of the Act by considering certain purchases as non-genuine. As the grounds raised in Revenue’s appeal also pertain to the part-deletion ... done with the afore-noted vendors were incurred wholly and exclusively for the purpose of business. Consequently, the said expenditure was disallowed under section 37(1) of the Act and added to the total income of the assessee. 9. The learned CIT(A), vide impugned order, after considering the submissions

Kalpataru Projects International Ltd, Mumbai vs. DCIT, CC-3(3), Mumbai

In the result, the appeals by the assessee for the assessment years

ITA 5965/MUM/2025[2013-14]Status: DisposedITAT Mumbai24 Dec 2025AY 2013-14

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT-DR
Section 147Section 148Section 250Section 37(1)

learned Authorised Representative (“learned AR”), at the outset, wishes to argue the ground raised on merits pertaining to the disallowance made under section 37(1) of the Act by considering certain purchases as non-genuine. As the grounds raised in Revenue’s appeal also pertain to the part-deletion ... done with the afore-noted vendors were incurred wholly and exclusively for the purpose of business. Consequently, the said expenditure was disallowed under section 37(1) of the Act and added to the total income of the assessee. 9. The learned CIT(A), vide impugned order, after considering the submissions

Kalpataru Projects International Ltd, Mumbai vs. DCIT, CC-3(3), Mumbai

In the result, the appeals by the assessee for the assessment years

ITA 5964/MUM/2025[2014-15]Status: DisposedITAT Mumbai24 Dec 2025AY 2014-15

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT-DR
Section 147Section 148Section 250Section 37(1)

learned Authorised Representative (“learned AR”), at the outset, wishes to argue the ground raised on merits pertaining to the disallowance made under section 37(1) of the Act by considering certain purchases as non-genuine. As the grounds raised in Revenue’s appeal also pertain to the part-deletion ... done with the afore-noted vendors were incurred wholly and exclusively for the purpose of business. Consequently, the said expenditure was disallowed under section 37(1) of the Act and added to the total income of the assessee. 9. The learned CIT(A), vide impugned order, after considering the submissions

Kalpataru Projects International Ltd, Mumbai vs. DCIT, CC-3(3), Mumbai

In the result, the appeals by the assessee for the assessment years

ITA 5963/MUM/2025[2015-16]Status: DisposedITAT Mumbai24 Dec 2025AY 2015-16

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT-DR
Section 147Section 148Section 250Section 37(1)

learned Authorised Representative (“learned AR”), at the outset, wishes to argue the ground raised on merits pertaining to the disallowance made under section 37(1) of the Act by considering certain purchases as non-genuine. As the grounds raised in Revenue’s appeal also pertain to the part-deletion ... done with the afore-noted vendors were incurred wholly and exclusively for the purpose of business. Consequently, the said expenditure was disallowed under section 37(1) of the Act and added to the total income of the assessee. 9. The learned CIT(A), vide impugned order, after considering the submissions

Kalpataru Projects International Ltd, Mumbai vs. DCIT, CC-3(3), Mumbai

In the result, the appeals by the assessee for the assessment years

ITA 5962/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Dec 2025AY 2017-18

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT-DR
Section 147Section 148Section 250Section 37(1)

learned Authorised Representative (“learned AR”), at the outset, wishes to argue the ground raised on merits pertaining to the disallowance made under section 37(1) of the Act by considering certain purchases as non-genuine. As the grounds raised in Revenue’s appeal also pertain to the part-deletion ... done with the afore-noted vendors were incurred wholly and exclusively for the purpose of business. Consequently, the said expenditure was disallowed under section 37(1) of the Act and added to the total income of the assessee. 9. The learned CIT(A), vide impugned order, after considering the submissions

Sunita Grovar, Panipat, Haryana vs. Principal Commissioner of Income-Tax, Rohta, Rohtak Haryana

In the result, appeal of the assessee is allowed

ITA 3608/DEL/2025[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri Vimal Kumar & Smt. Renu Jauhriassessment Year: 2018-19 Sunita Grover, Vs. Principal Commissioner Of Income T-7, Industrial Area, Panipat, Tax, Rohtak Pin: 132 103 (Haryana) Haryana Pan: Afmpg8500N (Appellant) (Respondent)

Section 115BSection 147Section 263

nowhere in the assessment order, the AO raised any doubts about the source of such purchases. Therefore, he invoked the provisions of section 37(1) of the Act and disallowed the purchases made by the assessee. This being so, the provisions of section 69C of the Act are not applicable

Deputy Commissioner of Income Tax, Mumbai vs. Welspun Enterprises Limited, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3625/MUM/2024[2013-14]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-14

Bench: Shri Justice (Retd.) C. V. Bhadang & Shri Prabhash Shankar

For Appellant: Shri Harsh Kapadia & Ajay Nagpal, ARsFor Respondent: Shri Arun Kanti Datta, (CIT-DR)
Section 115JSection 132Section 143(3)Section 153A

contentions of the assessee. There is absolutely no infirmity in the findings and the decision arrived at by the ld.CIT(A).Section 37(1) of the Act is a residual provision that allows businesses to deduct revenue expenditures not specifically covered under Sections 30 to 36, provided they meet certain ... personal expense and must be incurred "wholly and exclusively" for the purpose of the business or profession. To claim a deduction under Section 37(1), the following cumulative conditions must be met: -The expenditure must be revenue in nature, not a capital expenditure . -It must not be a personal expense

Jakson Limited, Delhi vs. DCIT, CC-4, Delhi

In the result, the appeal of the assessee is allowed and both the appeals of revenue are dismissed

ITA 5014/DEL/2024[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhri

For Appellant: Shri S.S. Nagar, CAFor Respondent: Shri Chandra Bhanu Mandal, SR. DR
Section 115JSection 147Section 15Section 250Section 37(1)Section 69CSection 80G

ITA No. 5014, 5010, 4987/DEL/2024 ACIT VS JAKSON LTD. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’, NEW DELHI

ACIT, New Delhi vs. Jakson Limited, Delhi

In the result, the appeal of the assessee is allowed and both the appeals of revenue are dismissed

ITA 5010/DEL/2024[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhri

For Appellant: Shri S.S. Nagar, CAFor Respondent: Shri Chandra Bhanu Mandal, SR. DR
Section 115JSection 147Section 15Section 250Section 37(1)Section 69CSection 80G

ITA No. 5014, 5010, 4987/DEL/2024 ACIT VS JAKSON LTD. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’, NEW DELHI

ACIT, New Delhi vs. Jakson Limited, Delhi

In the result, the appeal of the assessee is allowed and both the appeals of revenue are dismissed

ITA 4987/DEL/2024[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhri

For Appellant: Shri S.S. Nagar, CAFor Respondent: Shri Chandra Bhanu Mandal, SR. DR
Section 115JSection 147Section 15Section 250Section 37(1)Section 69CSection 80G

ITA No. 5014, 5010, 4987/DEL/2024 ACIT VS JAKSON LTD. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’, NEW DELHI

DCIT, Central Circle-20, Delhi vs. Lotus Herbals Pvt. Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 2445/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

sustainable in law in view of the following: Re (i): AMP Expenses incurred wholly and exclusively for assessee's business and allowable under section 37(1) of the Act The assessee is engaged in the FMCG industry, specifically cosmetic and skin care products, for the last more than ... exclusively to the trading business of the assessee. In view of above, AMP expenses incurred by the assessee are allowable business expenditure under section 37(1) of the Act. In fact, it is not even the case of AO that any part of AMP expenditure incurred and claimed

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2023[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

sustainable in law in view of the following: Re (i): AMP Expenses incurred wholly and exclusively for assessee's business and allowable under section 37(1) of the Act The assessee is engaged in the FMCG industry, specifically cosmetic and skin care products, for the last more than ... exclusively to the trading business of the assessee. In view of above, AMP expenses incurred by the assessee are allowable business expenditure under section 37(1) of the Act. In fact, it is not even the case of AO that any part of AMP expenditure incurred and claimed

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2023[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

sustainable in law in view of the following: Re (i): AMP Expenses incurred wholly and exclusively for assessee's business and allowable under section 37(1) of the Act The assessee is engaged in the FMCG industry, specifically cosmetic and skin care products, for the last more than ... exclusively to the trading business of the assessee. In view of above, AMP expenses incurred by the assessee are allowable business expenditure under section 37(1) of the Act. In fact, it is not even the case of AO that any part of AMP expenditure incurred and claimed