Raja Abhishek For NIRC 2024
2 months ago
š§š²š¹š®š»š“š®š»š® šš¶š“šµ šš¼ššæš š„šš¹š¶š»š“ š¼š» šš²š±šš°šš¶š¼š» š¼š³ šš š½š²š»š±š¶šššæš²š š³š¼šæ š¢šš²šæšš²š²š¶š»š“ š£šæš¼š·š²š°šš š¢ The bench of Justice P. Sam Koshy and Justice Laxmi Narayana Alishetty stated,
"For an expenditure to qualify for deduction under Section 37, it must be incurred for the business carried on by the assessee and must be spent wholly and exclusively for its own business."
š šš®š°šš: - šš¼šŗš½š®š»š: M/s Pipelic Energy Software India Pvt. Ltd. - ššššš²: The appellant sought to deduct expenses incurred for overseeing its holding company's project as business losses.
- š£šæš¼š°š²š²š±š¶š»š“š: The Assessing Officer disallowed the claim, stating the expenses were not for the appellant's business. The CIT(A) initially allowed the expenses, but the Tribunal reversed this decision.
āļø ššš±š“š²šŗš²š»š: The Telangana High Court upheld the Tribunal's ruling, confirming that expenses incurred for overseeing the holding company's project
cannot be considered revenue expenditures of the appellant and are not deductible under Section 37 of the Income Tax Act, 1961.
šš®šš² šš»š³š¼šæšŗš®šš¶š¼š»: - š§š¶šš¹š²: M/s Pipelic Energy Software India Pvt. Ltd. vs. The Deputy Commissioner of Income Tax - šš®šš² š”š¼.: Income Tax Tribunal Appeal No. 561 Of 2006
š This ruling emphasizes the need for businesses to distinguish between their own operational expenses and those incurred for the benefit of a holding company. #arr4nirc #abhishekrajaram #TelanganaHighCourt #IncomeTax #LegalUpdate
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