Alok Ferro Alloys Ltd. v. DCIT (2023) 203 ITD 199 (Raipur) (Trib.)

S. 37(1) : Business expenditure-Pooja and festival-Not allowable as business expenditure-Depreciation-Additional depreciation-Not produced relevant material-Matter remanded to the Assessing Officer. [S. 32 (1)(iia)]

Held that expenditure incurred towards pooja and festival by assessee company could not be treated as expenditure incurred wholly and exclusively for purposes of business or profession of a company  hence not allowable. Followed  Hira Ferro Alloys Ltd. v. Dy. CIT (2010)) 326 ITR 261 /(2009) 227 CTR 508 ((Chhattishgarh)(HC)  As regards additional depreciation,  since assessee had not brought on record any relevant details pertaining to additions in plant and machinery and with respect to use of impugned plant and machinery for year under consideration, matter was to be remanded back to Assessing Officer to adjudicate issue afresh. (AY. 2012-13)

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