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2010 (7) TMI 157 - DELHI HIGH COURTReopening of a completed assessment - Main contention of the assessee was that all the relevant facts in this behalf were placed before the AO when the assessment was carried out in the first instance and the AO had taken a categorical view that the entire expenditure was in the nature of revenue expenditure and therefore, liable for deduction – Held that: - the learned counsel for the Revenue has made altogether different submission before us. She argued that in the “reasons to believe” recorded by the AO while reopening the assessment, three aspects were noted. Apart from the aforesaid question relating to the expenditure in the assessee’s plan to expand its product range into higher horse power tractor segment, higher horse power tractors, etc. and the part of the expenditure thereupon, revenue or capital in nature, she pointed out that there were two more reasons given by the AO in his “reasons to believe” - it is not permissible for the learned counsel for the Revenue to now raise such a contention.
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