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2021 (8) TMI 99 - AT - Income TaxAllowability of harvesting and transport expenses paid by the Co-operative Sugar Mills to its farmers / members for purchase of sugarcane - HELD THAT:- The CBDT Circular No.6/2017 dt.10.10.2017 had clarified that the expenses incurred by the Co-operative Sugar Mills on harvesting and transport expenses for procuring the sugarcane from the farmers is allowed as deduction. Hon’ble jurisdictional High Court in the case CIT Vs. Manjara Shetkari Sahakari Sakhar Karkhana Ltd.. [2007 (8) TMI 260 - BOMBAY HIGH COURT]held that the expenditure incurred on the consideration of business expediency should be allowed as revenue expenditure. Similarly, the Hon’ble Madras High Court in the case of CIT Vs. Aruna Sunrise Hotels Ltd [2018 (5) TMI 156 - MADRAS HIGH COURT] held that the payment made to sugarcane growers / members in excess of the administered price determined by the Sugarcane Control Order, 1966 is eligible to be treated as an allowable as the revenue expenditure exclusively incurred for the purpose of business. We find that the order of ld.CIT(A) is in consonance with the CBDT Circular as well as the law laid down by the Hon’ble jurisdictional High Court and the Hon’ble Madras High Court cited supra, no contrary position has been pointed out to us by the ld. CIT D.R. and therefore, we do not see any reason to interfere with the order of ld.CIT(A). Accordingly, the appeal filed by the Revenue is dismissed.
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