2013 (12) TMI 1048

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....e relevant facts of the case are that the assessee company is the call centre/ BPO division who had debited an amount of amount of Rs.39,55,939/- to the P&L account towards Recruitment and Training expenses. The AO on a perusal of the details furnished by the assessee, observed that an expenditure of Rs.26,98,814/- had been incurred on the training expenses of staff members. Noting that the payment had been made to a related party and holding that the benefit of training to the staff members is of enduring nature the AO disallowed the said amount holding the same to represent capital expenditure. 3. In appeal before the First Appellate Authority, reliance was placed upon the submission made before the CIT(A) in 2007-08 assessment year as t....

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....:-    16. Under the head recruitment and training expenses and amount of Rs.1,37,79,797 was debited, out of which on amount of Rs.77,15,000 was incurred on training expenses of staff members. The AO disallowed this expenditure holding it in the nature of capital expenditure since the training of the staff members was of enduring nature. The appellant in this regard has stated that the recruited staff has to be specifically trained for voice and accent of UK & US for a period of about 2 weeks for operations of Call Center and BPO services. These expenses had been incurred wholly and exclusively for the purpose of business of Call Center business of the appellant and the same therefore, cannot be treated as capital in nature. The a....