https://www.taxtmi.com/caselaws?id=783808 The dominant issue was whether advances/deposits written off as "administrative expenses" were allowable as a revenue deduction under s.37(1) or as a business loss under s.28, or were in substance capital outlay towards acquisition of an MRI machine. The Tribunal held that the CIT(A) allowed the claim without examining whether any expenditure or business loss arose in the course of business, whether the transaction had business rationale, whether the recipient attempted to purchase the asset, and whether the assessee carried on a money-lending business; the CIT(A) also failed to analyze the timing and substance of successive agreements and to consider the SC ruling in Khyati Realtors. The matter was remanded to the CIT(A) for fresh adjudication, and the Revenue's appeal was allowed for statistical purposes. en-us Mon, 15 Dec 2025 00:00:00 +0530 Tue, 23 Dec 2025 07:59:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783808 The dominant issue was whether advances/deposits written off as "administrative expenses" were allowable as a revenue deduction under s.37(1) or as a business loss under s.28, or were in substance capital outlay towards acquisition of an MRI machine. The Tribunal held that the CIT(A) allowed the claim without examining whether any expenditure or business loss arose in the course of business, whether the transaction had business rationale, whether the recipient attempted to purchase the asset, and whether the assessee carried on a money-lending business; the CIT(A) also failed to analyze the timing and substance of successive agreements and to consider the SC ruling in Khyati Realtors. The matter was remanded to the CIT(A) for fresh adjudication, and the Revenue's appeal was allowed for statistical purposes. Case-Laws Income Tax Mon, 15 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783808