Deferred Revenue Expenditure: - In some cases, the
benefit of a revenue expenditure may be available for period of two or three or
even more years. Such expenditure is then known as "Deferred Revenue Expenditure" and is written off over a
period of a few years and not wholly in the year in which it is incurred. For
example, a new firm may advertise very heavily in the beginning to capture a
position in the market. The benefit of this advertising campaign will last
quite a few years. It will be better to write off the expenditure in there or
four and not in the first year.
When loss of a specially heavy and exceptional nature is sustained, it can also treated as deferred revenue expenditure. But, it should be noted, loss resulting from transactions entered into, such as speculative purchase or sale of a large quantity of a commodity, cannot be treated as deferred revenue expenditure. Only loss arising from circumstances beyond one's control can be so treated.
When loss of a specially heavy and exceptional nature is sustained, it can also treated as deferred revenue expenditure. But, it should be noted, loss resulting from transactions entered into, such as speculative purchase or sale of a large quantity of a commodity, cannot be treated as deferred revenue expenditure. Only loss arising from circumstances beyond one's control can be so treated.
The concept of deferred revenue expenditure
is not in the Income Tax Act. So, there is no clear provision under the I.T.
act about its allowance from business income. The concept of deferred revenue
expenditure is essentially an accounting concept and alien to the Act.
The nature of expenditure such as
advertisement or exhibition, sales promotion or fixed deposit etc. is such that,
although the benefit arising there from may extend over several accounting periods,
the same cannot be clearly and definitively assigned over time since the same
is intangible in nature.
The concept of deferred revenue expenditure
is essentially an accounting concept and alien to the Act. Deferred revenue
expenditure denotes expenditure for which a payment has been made or a liability
incurred, which is essentially revenue in nature but which for various reasons
like quantum and period of expected future benefit etc, is written-off over a
period of time e.g. expenditure on advertisement, sales promotion etc.
However, law is settled that accounting
practice can not determine allowability of an expense under Income Tax Act.
Basic principal of Deferred Revenue
Expenditure
The basic principle which determines whether
differed revenue expenditure can be allowed in full can be summed up as follows:-
1. Where
expenditure treated as“deferred revenue expenditure” results in the creation of
any capital asset (tangible or intangible), a case can be made out to treat the
same as a capital expenditure with corresponding allowability of depreciation
in accordance with law;
2. In
cases where the nature of the revenue expenditure is such that the same can be
clearly and unambiguously identified over specified future time periods (e.g.
discount on issue of debentures) akin to prepaid expenses the same would be
allowable over the period to which these relate proportionately, applying the
matching principle.
3. In
other cases where the same does not result in the creation of any capital asset
or where the same is not allocable over defined future time periods there can
be no case for amortizing the same under the Act over the expected period over
which the benefit is likely to arise there from since in such cases the
expenditure is essentially revenue in nature but is amortized in the books only
on account of some other considerations.
Therefore, one can say that in every case
where the expenditure on sales promotions, advertisements etc are made and no
capital asset is generated out of it , in that case even if the assessee has
amortized the expense over a number of years, expense can be claimed as fully
allowable expense in the year in which it is actually incurred.
Differed revenue considered as fictitious
asset
Fictitious assets-fictitious assets are deferred
revenue expenditure whose benefit is derived over long period of time .Even accumulated
losses are also fictitious assets as they are written off over a period of
time. All fictitious assets are intangible but all intangible assets are not
fictitious (ex goodwill, patents, trademarks, copyrights are intangible but not
fictitious. Following are the examples of fictitious assets are-preliminary expenses,
discount on issue on debenture and shares, underwriting commission, miscellaneous
expenditure, profit and loss (dr).
