https://www.taxtmi.com/caselaws?id=17881 The court clarified that Section 37(3A) of the Income-tax Act, 1961 operates independently of Section 37(1) and the nature of expenditure is irrelevant for its application. It held that the Tribunal erred in considering the nature of the expenditure and directed that deductions under Section 37(3A) should be based on aggregate expenditure without regard to its capital or revenue nature. The court also determined that the subsidy received by the assessee constitutes income and found that the Tribunal exceeded its jurisdiction by allowing a claim not raised before lower authorities. The court ruled against the assessee in all relevant questions, favoring the Revenue. en-us Mon, 02 Sep 1996 00:00:00 +0530 Fri, 25 Sep 2009 13:34:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=17881 The court clarified that Section 37(3A) of the Income-tax Act, 1961 operates independently of Section 37(1) and the nature of expenditure is irrelevant for its application. It held that the Tribunal erred in considering the nature of the expenditure and directed that deductions under Section 37(3A) should be based on aggregate expenditure without regard to its capital or revenue nature. The court also determined that the subsidy received by the assessee constitutes income and found that the Tribunal exceeded its jurisdiction by allowing a claim not raised before lower authorities. The court ruled against the assessee in all relevant questions, favoring the Revenue. Case-Laws Income Tax Mon, 02 Sep 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=17881