Club Membership Fees Allowable as Business Expenditure: ITAT Relies on SC Precedent

Punjab National Bank Vs DCIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT) Delhi, in a recent ruling for Assessment Year 2018-19, has sided with Punjab National Bank (PNB) regarding the disallowance of club subscription fees totaling Rs. 12,62,175. The bank had appealed against the decision of the CIT(A)/NFAC, which upheld the Assessing Officer’s disallowance. The dispute centered on whether the club fees, paid for memberships including Mayar Health Resorts Ltd. and Taj, were incurred “wholly and exclusively for the purpose of business” under Section 37 of the Income ...