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2017 (1) TMI 894 - AT - Income TaxRevision u/s 263 - nature of modification and improvement expenditure leasehold Workshop - CIT observed that in view of the Explanation 1 to Section 32(1) inserted with effect from 01/04/1988, the assessee-firm's claim of allowance of said sum under revenue expenditure is not correct and the expenditure is however eligible for depreciation in accordance with the Explanation 1 to Section 32(1) - Held that:- The assessee has taken on lease the semifinished building with other structure and the assessee had made the modification and improvement to the semi-finished structure to suit the requirement of work shop (refer page 21 of paper book). Hence the assessee has only modified and improved the leased property to suit the requirement of its business. Hence, the explanation “1A” to section 32 will apply to the assessee’s case and the findings of ld. CIT is proper. Accordingly, we are inclined to uphold the order of CIT passed u/s 263 of the Act. - Decided against assessee
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