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2019 (6) TMI 1126 - HC - Income TaxDisallowance of expenses incurred towards fertility improvement programme - nature of expenditure - revenue or capital expenditure - HELD THAT:- Question raised are no longer res integra in view of the decision of this Court in the case of Pr. CIT vs. Gujarat Cop, Op. Milk Marketing Fedaration Ltd. . [2018 (10) TMI 1385 - GUJARAT HIGH COURT] as part of the programme, the GCMMF would address the typical reasons for infertility such as improper practice in calf rearing, low body weight of animals, lack of nutrition/mineral, poor health condition, lack of awareness amongst farmers about improved breeding practices etc. In furtherance of such objectives, the GCMMF would hold camps for village awareness, in select villages would carry out tagging and registration of animals, would hold fertility camps, would carry out mass deworming programmes, would distribute mineral mixture, carry out vaccination at mass scale, provide balanced cattle feed etc. Thus seen that the expenditure was general in nature and aimed at improving the practices for better fertility amongst milk animals by addressing the issues which caused infertility. The expenditure therefore was for the purpose of its business and would not be corelatable to any tangible returns which can be expected out of such expenditure. Also confirmed by SC. [2019 (6) TMI 1104 - SC ORDER] - Decided in favour of assessee.
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