S.37(1): Business expenditure-Salary to employees-No disallowance was proposed in the show-cause notice-Order of CIT(A) deleting the disallowance was affirmed.
ITO v. Rajeshkumar Rameshchandra Shah. (2025) 214 ITD 725 (Ahd) (Trib.)S.37(1): Business expenditure-Salary to employees-No disallowance was proposed in the show-cause notice-Order of CIT(A) deleting the disallowance was affirmed.
ITO v. Rajeshkumar Rameshchandra Shah. (2025) 214 ITD 725 (Ahd) (Trib.)S.37(1): Business expenditure-Insurance premium-Loan to firm on an insurance policy on the life of one of its partners-Insurance premium paid allowable as a deduction.
Pankaj Enterprises. v. DCIT (2025) 214 ITD 702 (Mum) (Trib.)S.37(1): Business expenditure-Setting up of business-Power Purchase Agreement-Expenditure incurred for the purpose of business after setting up of business was allowable for deduction.
Shapoorji Pallonji Energy (Gujarat) (P) Ltd. v. DCIT (2025) 214 ITD 297 (Mum) (Trib.)S.37(1): Business expenditure-towards Employee Stock Option Plan (ESOP)-International Stock Ownership Plan (ISOP)-Paid to parent company-Allowable as deduction.
Procter & Gamble Hygiene and Health Care Ltd v. NFAC (2025) 214 ITD 315 (Mum) (Trib.)S. 36(1)(viii): Eligible business-Special reserve-Minimum alternate tax-Taxable in the year in which the amount is withdrawn from such reserve-Amount transferred to reserve under section 36(1)(viii) shall not be included in book profit under section 115JB.[S.115JB]
SREI Equipment Finance Ltd. v. CIT (Appeals) (2025) 214 ITD 769 (Kol) (Trib.)S. 36(1)(vii): Bad debt-Subsidy-Offered as income in earlier years-Unrecoverable subsidy allowable as bad debt.
Indian Potash Ltd. v. DCIT (2025) 214 ITD 121 (Delhi) (Trib.)S. 36(1)(va): Any sum received from employees-Deposited ESI contribution on 16-10-2017 for September 2017, when the due date was 15-10-2017, which happened to be a public holiday, i.e., Sunday-One day delay on account of a public holiday-Allowable deduction. [S.43B General Clauses Act, 1897, S.10]
SREI Equipment Finance Ltd. v. CIT (Appeals) (2025) 214 ITD 769 (Kol) (Trib.)S. 36(1)(iii): Interest on borrowed capital-sufficient non-interest-bearing funds–car loan–disallowance of interest is not justified.
Patidar Builder (P.) Ltd. v. Assessing Officer (2025) 214 ITD 77 (Indore) (Trib.)S. 32: Depreciation-Goodwill-Intangible asset-Purchased goodwill as it involves cost and is recognised as an intangible asset in accounting in the successor company-Depreciation allowable.[S. 55]
Sagarlaxmi Agriseeds (P) Ltd. v. ACIT (2025) 214 ITD 204 (Ahd) (Trib.)S. 32: Depreciation-Carry forward and set off-Unabsorbed depreciation as current year’s depreciation-Set-off against income under any head, including income from other sources-Provision does not mandate that business be carried on in relevant year, nor limit adjustment to business income.[S. 32(2), 72]
Parshwanath Land Organisers LLP. v. ITO (2025) 214 ITD 173 (Ahd) (Trib.)