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2012 (7) TMI 541 - AT - Income TaxRevenue or capital Expenditure - purchase of tin plates for advertisement and publicity – Held that:- These tin plates were not of a life which can provide benefit of enduring nature - in the past and subsequent years, such expenditure has been treated as revenue in nature and without any cogent reason, the revenue should not have disturbed the same - no fault in the order of the CIT (A) in granting the relief. Reassessment proceedings – Held that:- Assessing Officer while finalizing the initial assessment has not applied his mind - No discussion has been made about this particular expenditure in the assessment order - reply of the assessee to the query is also silent on the issue, thus it is clear from the records that the assessment order was passed without any application of mind and such non-application of mind is clear from the order of the assessment itself - no fault in the order of CIT (A) in upholding the reopening of the assessment proceedings
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