Section 271(1)(c) – CA’s Opinion Does Not Make Claim Bona Fide

Chadha Sugars Pvt. Ltd Vs. ACIT (ITAT Delhi) – The facts are that the assessee claimed an expenditure of Rs. 7,80,500/-, being the fees paid to Registrar of Companies for raising authorized capital. It is the admitted position of law that the expenditure is not revenue in nature and, therefore, it is not deductible in computing the total income. It is also the admitted fact that two decisions of the Supreme Court, adverse to the assessee, held field when the return was filed. This means that the claim is patently dis allowable. It is also a fact that the claim is not discernible on the f...