9911796707
TMI Blog2019 (9) TMI 858X X X X Extracts X X X X X X X X Extracts X X X X ..... 11/02/2013 by the ld. Dy. Commissioner of Income Tax - 9(2), Mumbai(hereinafter referred to as ld. AO). 2. The only issue to be decided in this appeal is as to whether the ld CITA was justified in confirming the action of the ld AO of treating the entire expenditure of Rs. 1,09,84,625/- debited to profit and loss account as expenditure pertaining to commercial project and capitalized to work in progress, in the facts and circumstances of the case. 3. We have heard the rival submissions. We find that the assessee is engaged in the business of real estate development of hotel, retail, mall, information technology park and other high quality commercial segments and had filed the return of income for the Asst Year 2010-11 on 10.9.2010 declar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ,560 Administrative charges, HR Accounting, Finance. Payroll, taxation etc. 6 Travelling and conveyance 11,56,447 Routine travel and related expenses 7 Communication costs 37,713 Telephone charges 8 Repairs and maintenance 4,43,785 Various AMC & internet charges at corporate office 9 Audit fees 7,49,488 Statutory Audit Fees 10 Royalty charges 17,35,524 For use of name and logo 11 Bank charges 48,202 Routine bank charges 12 Subscription charges 56,500 Subscription to Export promotion council and business association 13 Advertisement and Publicity expenses 5,29,524 Market Survey and research reports 14 Miscellaneous expenses 1,13,155 Various day to day small nature expenses at c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reatment of expenditure i.e partly towards capital work in progress in respect of direct project related expenses and partly towards revenue expenditure in respect of routine administrative expenses has been consistently followed by the assessee in the earlier years also and the same stand was taken by the assessee during the year under consideration. We find that there is no reason for the ld AO to take a divergent stand with regard to the treatment of expenditure given by the assessee in the books which is similar to treatment for income tax purposes also. In any case, we find that these administrative expenses , even if transferred to capital work in progress, would eventually find its way to the profit and loss account in the year of co ..... X X X X Extracts X X X X X X X X Extracts X X X X
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