Tata Steel Ltd. v. Dy. CIT (2024)109 ITR 18 (Mum) (Trib)

S.37(1): Business expenditure-Compensatory afforestation 1Capital or revenue 1No enduring benefit from incurrence Expenditure is allowable as revenue expenditure. [S. 145]

Held that  expenditure on compensatory afforestation, such payments were governed by various Acts with the Supreme Court making a ruling for State Governments to participate in the granting of mining leases by recovering compensation when their forests were uprooted. The funds were used for natural regeneration in which the assessee participated indirectly. It could not be said that the assessee had incurred capital expenditure giving it a benefit of enduring nature. The amount was incurred as revenue expenditure and is allowable  in the year of incurrence. (AY.2019-20)

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