TMI Blog2018 (3) TMI 1088X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee reduced from the gross value of assets from the schedule of fixed assets under the Companies Act, 1956. The Tribunal noted that all the facts in relation thereto were disclosed by the assessee. The assessee took a position which the Tribunal held was a possible one. The Tribunal further held that merely because the judgements ultimately took a contrary view it would not warrant the imposi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 018 - MR. S. J. VAZIFDAR, CJ. AND MR. AVNEESH JHINGAN, J. For The Appellant : Mr. Tajender K. Joshi, Advocate ORDER S.J. VAZIFDAR, C.J. (ORAL) This is an appeal against the order of the Income Tax Appellate Tribunal deleting the penalty imposed by the Assessing Officer and upheld by the CIT (Appeals). The matter pertains to the assessment year 2005-2006. 2. The or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the purchase of software by the assessee to carry out its business activities in a more efficient manner. The assessee claimed the same to be revenue expenditure, whereas the Assessing Officer treated the same as capital in nature. The Tribunal noted that a judgement of the Division Bench of the Delhi High Court in CIT Vs GE Capital Services Ltd. (2008) 300 ITR 420 (Del) supported the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X
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