TMI Blog2020 (5) TMI 667X X X X Extracts X X X X X X X X Extracts X X X X ..... admitted by learned CIT(A) that this payment in question will help the firm in getting goodwill of local citizens, bureaucrats, politicians, press and others, this will definitely benefit the assessee firm s business also, may at a later date. Therefore, in our considered opinion, this expenditure is an allowable expenditure under section 37(1) - Decided in favour of assessee. - ITA No.504/Bang/2014 - - - Dated:- 29-5-2020 - Shri A. K. Garodia, Accountant Member And Shri Pavan Kumar Gadale, Judicial Member Assessee by: Shri.B. S. Balachandran, Advocate Revenue by: Shri. A. Ramesh Kumar, JCIT (DR)(ITAT), Bengaluru ORDER A.K. Garodia, This appeal is filed by the assessee and the same is directed against the orde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ner for the purpose of Hampi Utsav. The AO held that this expenditure is not incurred for the purpose of business and therefore, cannot be allowed as expenditure under section 37 of the Income Tax Act, 1961. By making this observation, he made the disallowance and when the assessee carried the matter in appeal before the learned CIT(A), learned CIT(A) upheld the Assessment Order and now the assessee is in further appeal before us. 4. In the course of hearing, the learned AR of the assessee placed reliance on the judgment of Hon ble Karnataka High Court rendered in the case of M/s. Kanhaiyalal Dudheria Vs. JCIT in ITA Nos.100016 and 100017/2018 dated 31.07.2009, copy available on pages 16-50 of the Paper Book. In particular, our attention ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... TR 174 (Karnataka) was noted and it was also noted that in this case, the issue in dispute was regarding the expenditure incurred by the assessee for installing the traffic signals as business expenditure under section 37(1) of the Income Tax Act, 1961 and it was held that for the purpose of business used in section 37(1) of the Income Tax Act, 1961, it should not be limited to meaning of earning profit alone and it includes providing facility to its employees also for the efficient working. 5. As against this, learned DR of the Revenue supported the order of CIT(A) and in particular, our attention was drawn to para 2 on page 4 of the order of CIT(A) and it was pointed out that in this para, it is noted by learned CIT(A) that the payment ..... X X X X Extracts X X X X X X X X Extracts X X X X
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