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2019 (3) TMI 287 - HC - Income TaxNature of expenditure - revenue or capital expenditure - expenditures towards repairs and renovations of Assessee's hotel properties - HELD THAT:- Here it cannot be said that the expenditure incurred was for the purpose of bringing into existence a new asset or obtaining a new advantage. This was as simple case where the existing assets were repaired, or to some extent renovated. The CIT Appeals, as well as the ITAT, on facts, have held that this was not a case where some new asset was brought into existence or new advantage of enduring nature was obtained. Such concurrent findings of fact do not suffer from any perversity, so as to give rise to any substantial question of law. Depreciation on UPS - @60% OR 15% - UPS is the component/ equipment connected with the computers - HELD THAT:- Both, the CIT Appeals, as well as the ITAT have relied upon the decisions in the case of CIT vs. BSES Yamuna Powers Ltd [2010 (8) TMI 58 - DELHI HIGH COURT], Pentair Water India (P) Ltd. vs. ACIT [2014 (5) TMI 1068 - ITAT PANAJI] and Macawber Engineering System (I) P. Ltd. vs. ACIT (2013 (11) TMI 131 - ITAT MUMBAI) in which it is clearly held that the UPS is the component/ equipment connected with the computers and is, therefore, entitled for the depreciation @ 60%. Again, the contention, as raised, does not give rise to any substantial question of law.
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