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2014 (1) TMI 1636 - AT - Income TaxDisallowamce of Deferred revenue expenditure - Held that:- Expenditure was incurred on development of improvised version of the existing “wheel type” harvestor combine machines which the assessee was selling. Thus, the expenditure resulted in only improving the existing machine but did not bring into existence any new profit earning apparatus. Hence, it was in revenue field and not in capital field. The assessee had primarily claimed the expenditure in such a manner so that the entire expenditure is claimed over the period by which the product was expected to be commercially launched. - CIT(A) has rightly observed that assessee had not claimed the deferred revenue expenditure by way of amortization @ 10% for a period of 10 years. Further the assessee never represented that the deferred revenue expenses were of the nature of pre-operative expenses and, accordingly, never claimed them u/s 35D. - No reason to interfere with order of CIT(A) - Decided against Revenue.
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