https://www.taxtmi.com/caselaws?id=34366 HC upheld ITAT's view allowing pre-1.02.1996 expenses where the taxpayer had "set up" the business earlier. The AO and CIT(A) had disallowed deductions on the ground that business commenced only when a bank account opened on 1.02.1996, but ITAT found "setting up" under Section 3 differs from commencement and permits deduction for expenses incurred after setting up. HC held the question is fact-specific, refused to treat it as a substantial question of law, and dismissed the revenue's appeal. en-us Wed, 19 Aug 2009 00:00:00 +0530 Wed, 12 Nov 2025 17:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=34366 HC upheld ITAT's view allowing pre-1.02.1996 expenses where the taxpayer had "set up" the business earlier. The AO and CIT(A) had disallowed deductions on the ground that business commenced only when a bank account opened on 1.02.1996, but ITAT found "setting up" under Section 3 differs from commencement and permits deduction for expenses incurred after setting up. HC held the question is fact-specific, refused to treat it as a substantial question of law, and dismissed the revenue's appeal. Case-Laws Income Tax Wed, 19 Aug 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=34366