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2017 (2) TMI 272 - AT - Income TaxRevision u/s 263 - contribution to CAF - revenue or capital receipt - deferred revenue expenditure - Held that:- No point of time could it be said that the assessee had incurred capital expenditure giving the assessee a benefit of enduring nature for the purpose of earning segmented income to render the same to income tax. In other words, the authorities below have not pointed out the income generated against the purported deferred revenue expenditure so proposed by them in their impugned orders. The amount was incurred as a revenue expenditure to be allowed in the year it has been incurred. It is not in dispute that the said payment was made as contribution to compensatory afforestation as per the directions of the Supreme Court. It is not permissible for the assessee to make phase-wise payment. In that view, the order of the Appellate Tribunal is sound and proper. See Ramgad Minerals and Mining Pvt. Ld. [2012 (1) TMI 313 - Karnataka High Court] Interest u/s 234C - Held that:- Direct the A.O. to levy interest u/s 234C only on the basis of returned income of the assessee.
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