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2022 (1) TMI 246 - HC - Income TaxExpenditure allowable as business expenditure u/s 37(1) - expenditure on account of processing fees on a loan taken by the third party - what is the nature of transaction and as to how the CIT(A) held the expenditure to be of revenue in nature? - HELD THAT:- No uncertain terms held that CIT(A) has examined each and every aspect of the case and held in favour of the assessee. But with regard to the issue whether the expenditure is allowable as business expenditure, under Section 37(1) CIT(A) has taken note of the various decisions on the point, namely the positive test and the negative test, which are to be applied, and thereafter proceeded to examine the facts, and held that the case of the assessee is entirely different from that of the case of M/s Ruia Sons P Ltd. In this regard, it is relevant to take note of the finding recorded by the CIT(A). This finding was reexamined by the Tribunal and the Tribunal has on facts concurred with the CIT(A). No substantial questions of law.
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