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2016 (1) TMI 413 - AT - Income TaxDisallowance of expenditure for replacement cost of remembraining in membrance cell-III - Held that:- As decided in assess's own case the attempt to contend that life of membrane would be spread over from 3 to 5 years or that the amount involved for replacement of membrane is huge and, therefore, the departure on the part of the Revenue could be said as justified, in our view, cannot be countenance for two reasons. One is that the amount involved would not make difference for chargability of the tax but the nature of expenditure would be relevant for the chargability of tax. It hardly matters whether the amount is more or less. Further, on the aspect of life of the membrane, nothing is referred to by the A.O. nor by C.I.T. (Appeals) that earlier, such aspect, namely, life of the membrane spread over from 3 to 5 years was not considered or it had missed or otherwise. We find no infirmity in the order of CIT(A) and accordingly delete the addition and in the alternative allow the cost of remembraining in membrance cell-II as revenue expenditure. Decided in favour of the Assessee.
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