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2023 (11) TMI 39 - HC - Income TaxBad debts u/s 36(1) acquired from predecessor-in-interest - acquisition of commercial vehicle division in a scheme of demerger - HELD THAT:- This very issue has been decided by us today in an appeal concerning the respondent/assessee in VE Commercial Vehicles Ltd. [2023 (10) TMI 1283 - DELHI HIGH COURT] ruled issue in favour of the respondent/assessee as not disputed that the predecessor-in-interest had offered for imposition of tax the subject debts at a relevant point in time. See T. Veerabhadra Rao [1985 (7) TMI 2 - SUPREME COURT] and Times Business Solution Ltd. [2013 (4) TMI 370 - DELHI HIGH COURT] Nature of expenses - training expenses treated as a third kind of expense, i.e., deferred revenue expenditure - Tribunal holds that u/s 37 the entire expenditure would have to be allowed - HELD THAT:- According to us, the view taken by the Tribunal is correct. Also see CIT(A) vs. Samsung India Electronic Limited [2013 (7) TMI 365 - DELHI HIGH COURT] has taken the same view. Revenue appeal dismissed.
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