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2016 (5) TMI 352 - AT - Income TaxAddition of store relocation expenses - revenue v/s capital expenditure - Held that:- AO in the assessment year 2003-04 has already allowed the expenses by treating the same as revenue in nature. However, we are of the view that Revenue should not have filed this ground of appeal before the Tribunal, because the same expenses has already been admitted by the AO in his order dated 25.3.2015 relevant for the assessment year 2003-04. Following the consistent view adopted by the Revenue in the assessment year 2003-04 in assessee’s own case, we dismiss the ground raised by the revenue. - Decided against revenue Addition being debentures restructuring - revenue v/s capital expenditure - Held that:- Restructuring fees paid by the appellant to renegotiate the rate of interest on debentures represented the present value of differential rate of interest which should be allowed as revenue expenditure. See CIT vs. Gujarat Guardian Ltd [2009 (1) TMI 13 - HIGH COURT DELHI] - Decided against revenue
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