2026 (5) TMI 1424

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.... SSC with Mr. Apoorv Agarwal, Mr. Viplav Acharya, JSCs. For the Respondent Through: Mr. Satyen Sethi & Mr. Arta Trana Panda, Advocates. ORDER 1. Following substantial questions of law had been framed in the instant appeal vide order dated 04.08.2014:- "(i) Whether the Income Tax Appellate Tribunal was right in holding that interest due and payable under the award, operation of wh....

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....7 of the Income Tax Act, 1961?" 2. Mr. Satyen Sethi, learned counsel for the respondent, at the outset submitted that so far as first two questions are concerned, they don't require any adjudication as framed, because Hon'ble the Supreme Court vide its judgment dated 22.04.2020 rendered in the case of National Agricultural Co-operative Marketing Federation of India v. Alimenta S.A. reported in ....

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....t be claimed to be an expenditure incurred for the purpose of business of the Society. He argued that the expenses therefore, do not fall within the ambit of business expenditure as per Section 37 of the Income Tax Act, 1961. 6. He further submitted that the amount spent was excessive and thus, rightly been disallowed by the Assessing Officer. 7. Heard learned counsel for the parties. 8. ....

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....has been incurred on convening and in relation to meeting, it cannot be said that it is not a business expenditure. 11. According to us, business expenditure cannot be given restricted meaning and cannot be confined to only those expenditures which relate to purchase and sale or other directly relatable activities. Business expenditure as given under Section 37 of the Income Tax Act, 1961, has ....