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Judgment
ORDER
This assessee’s appeal for Assessment Year 2018-19 arises against the C IT(A)/NFAC, De lhi’ s DIN & order No. ITBA/NFAC/S/250/2025-26/1083790070(1) dated 17.12.2025, in proceed ings u/s 143(3) of the Income Tax Act, 1961 (in shor t “the Act”).
Heard both the p arties at length. Case file perused.
It is noticed at the outset during the co urse of hearing that the assessee/appellant is aggrieved against both the learned lower authorities’ respective findings disallowing it’s advertisement expenses, professional and miscellaneous expenditure; involving varying sums, for the sole reason that the same result in enduring bene fits and thus amount to capital expenditure only.
Faced with this situation, the Revenue could hardly dispute that the hon’b le apex court’s decision in Taparia Tools Ltd. vs. JCIT (2015) 372 ITR 605 (SC) has already settled the issue that such an expenditure claim could no t be disallo wed merely for the reason of y ield ing enduring benefits. T his is indeed co upled with the fact that the tribunal’s attentio n is invited to the assessee’s computation at page 3 wherein it has incurred total expenditure of Rs.1,40,50,029/- and claimed a portion thereof to the tune of Rs.19,88,191/- only. I find merit in the assessee’s instant sole substantive ground which is hereby accep ted in very terms.
This assessee’s appeal is allowed.
Order Pronounced in the Open Court o n 17/03/2026.