Vodafone Mobile Services Ltd. vs Deputy Commissioner Of Income Tax on 11 March, 2025
12. Mr. Jolly thus submitted that ARC would constitute expenditure
„....laid out or expended...‟ for the purposes of business and thus liable
to be factored in while computing income chargeable under the head of
profits and gains of business or profession. It was Mr. Jolly‟s
submission that Section 43 significantly uses the expression actual cost
of the assets „to the assessee‟ and thus clearly not contemplating costs
having been incurred in praesenti or on the date of preparation of the
Balance Sheet. It was submitted that the Madras High Court in M/S
Vedanta Limited vs. The Joint Commissioner of Income Tax8 had,
on a due review of the various precedents rendered in the context of a
provision being made as well as the Accounting Standards which apply
had come to explain the meaning to be ascribed to the phrase „....laid
out or expended..‟ in the following terms:-