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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Pawan Singh, JM, Arun Khodpia, AM
Deputy Commissioner of Income Tax, CIR 3(4) – Appellant
Versus
Bajaj Auto Limited – Respondent
| Table of Content |
|---|
| 1. appeal background and assessee's business facts (Para 1 , 2 , 3 , 4) |
| 2. dies and moulds expenditure is revenue nature (Para 5 , 6) |
| 3. suo moto 14a disallowance upheld absent ao dissatisfaction (Para 7) |
| 4. leasehold land premium deductible as revenue expenditure (Para 8) |
| 5. software expenses allowable as revenue expenditure (Para 9) |
| 6. provision for bad debts deductible per precedent (Para 10) |
| 7. foreign tax paid in chile deductible post-verification (Para 11 , 12) |
| 8. revenue appeal dismissed upholding cit(a) order (Para 13 , 14) |
ORDER
Per Arun Khodpia, AM:
The captioned appeal is filed by the revenue against the order of Commissioner of Income Tax (Appeals)/ National Faceless Appeal Centre (NFAC), Delhi [in short “Ld. CIT(A)”] dated 13.03.2025, relevant to Assessment Year (AY) 2020-21. The impugned appellate order was passed in appeal against the order u/s 143(3) of the Income Tax Act, 1961 (“the Act”) dated 29.09.2023, by the Assessment Unit, Income Tax Department. The grounds of appeal raised by the revenue are as under:
i) “Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in holding that expenditures on dies and moulds are reven
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