2025 (2) TMI 494

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..... fact that disallowance herein is that of "prior period" expenditure wherein the corresponding claim pertaining to the earlier assessment year has been recognized on the basis of its alleged crystalization in the relevant previous year. Case law PCIT v. Adani Enterprises [2016 (7) TMI 1250 - GUJARAT HIGH COURT] holds such an issue as an instance of revenue neutral expenditure which could not have .....

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..... ed during the course of hearing that both the lower authorities have rightly disallowed the assessee's "prior period" expenditure claim of Rs. 2,20,00,000/- in the course of assessment framed on 24.12.2019 as upheld in the lower appellate findings. 3. Faced with this situation, a perusal of the case file indicates that this assessee in fact is a company getting assessed at the maximum marginal ra .....

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