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        <h1>Court rules guest house expenses not deductible, emphasizing legislative intent and legal precedent.</h1> <h3>The Commissioner of Income Tax, Meerut And Another Versus M/s. Baghpat Co-Operative Sugar Mills Ltd.</h3> The Commissioner of Income Tax, Meerut And Another Versus M/s. Baghpat Co-Operative Sugar Mills Ltd. - [2014] 363 ITR 319 Issues:Income Tax Appeal related to Assessment Year 1997-98, Disallowance of Guest House Expenses, Interpretation of law based on Britannia Industries Ltd. case.Analysis:The appeal in question pertains to the Assessment Year 1997-98 and revolves around the disallowance of Guest House Expenses amounting to Rs.1,15,000. The primary legal issue raised is whether the Income Tax Appellate Tribunal erred in law by holding that the disallowance of the said expenses could not be made, contrary to the precedent set by the Hon'ble Supreme Court in the case of Britannia Industries Ltd. vs. CIT. The appellant's counsel argued that the issue at hand is covered by the judgment of the Apex Court in the Britannia Industries Ltd. case.Upon examination, it was found that the Assessing Officer had disallowed the Guest House Expenses, which was subsequently deleted by the Appellate Authority. However, the Department appealed this decision before the Tribunal, which dismissed the appeal in favor of the assessee based on a previous decision. The appellant's counsel contended that in light of the Britannia Industries Ltd. case, the Tribunal's view was no longer valid.The appellant's counsel specifically referred to paragraphs 11 and 30 of the Britannia Industries Ltd. judgment, highlighting the legislative intent behind the provisions related to the maintenance of residential accommodations like guest houses. The court emphasized that the language of the statute was clear and unambiguous, indicating that expenses towards guest houses were not allowable deductions. Consequently, both the Appellate Authority and the Tribunal were deemed to have erred in deleting the Assessing Officer's order disallowing the Guest House Expenses.In conclusion, the High Court allowed the appeal, answering Question No.3 in favor of the Revenue and against the assessee. The judgment underscored the importance of interpreting tax laws in accordance with clear legislative intent and established legal precedents like the Britannia Industries Ltd. case.

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