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Issues involved: The judgment deals with the question of whether expenses incurred by the assessee towards pooja and bakshish should be allowed as business expenses or welfare expenses of the staff.
Summary: The High Court of Madras considered the Commissioner of Income-tax's application for a direction to the Tribunal regarding the classification of expenses incurred by the assessee. The assessment years in question were 1968-69 and 1969-70, during which the assessee claimed miscellaneous expenses for pooja and bakshish. The Income Tax Officer (ITO) disallowed the claim, which was upheld by the Appellate Authority. However, the Income-tax Appellate Tribunal partially allowed the appeals, stating that the expenses were incurred for the welfare of the workers. The Tribunal found that the expenses on poojas, bakshish, and presentations were specifically for the workers, leading to the conclusion that they should be considered as welfare expenses. As these expenses were deemed to be for the workers' benefit, the Tribunal's decision was upheld by the High Court, dismissing the petitions with costs. The Court emphasized that no legal question arose from the Tribunal's order, as it was based on specific facts of the case.
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