ACIT v. Gujarat State Road Development Corporation Ltd. (2023) 202 ITD 510 (Ahd.)(Trib.)

S. 37(1) : Business expenditure-Expenditures towards road and bridge construction Commercial expediency-Allowable as deduction allowable as deduction though no income shown during the year. [S. 145]

Assessee claimed expenses towards certain projects. Assessing Officer disallowed said expenses on ground that this claim of expenses was made without corresponding disclosure of income against same. Tribunal held that  expenses were related to road and bridge construction which is  main object for which assessee-company had been incorporated. There is  no dispute that these expenses were incurred wholly and exclusively for purpose of business of assessee and satisfied test of commercial expediency as per provisions contained in section 37(1). Disallowance is deleted.(AY. 2010-11)