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The High Court of Allahabad addressed a case involving a limited company running a hotel claiming deduction for foreign travel expenses of its directors. The Income-tax Officer disallowed 2/3 of the claimed amount, stating that the expenditure was partly capital in nature due to the company's construction of new hotels. The Tribunal upheld this decision, ruling that the allocation of expenses was justified given the composite nature of the agreement with Ramada Inns. The court ruled in favor of the Revenue, affirming the allocation of expenses and denying the full deduction for the foreign tour expenses.
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