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2015 (6) TMI 900 - AT - Income TaxReopening of assessment - disallowance on account of deferred revenue expenditure - CIT|(A) deleted the disallowance - Held that:- The hon’ble jurisdictional High Court in DCIT vs. Core Healthcare Ltd., (2008 (10) TMI 74 - GUJARAT HIGH COURT) holds that an expenditure incurred at the time of installation of machinery in existing line of business resulting in enduring benefits cannot be held to be capital expenditure merely because some direct or indirect benefits; immediate or a period of time, flow from the same. The Revenue does not quote any case law to the contrary. We take cue therefrom and treat the entire expenses as revenue expenditure. An assessee can adopt the two ways of giving different accounting treatment to an expenditure in its books and claim the entire sum as revenue expenditure in the relevant assessment year. Therefore, we uphold the CIT(A)’s order deleting the impugned disallowance/addition of deferred revenue expenditure. The Revenue’s ground fails. - Decided in favour of assessee.
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