M/S. Alpha Design Technologies Private Limited, Bangalore vs. Income Tax Officer, Ward- 1(1)(2), Bangalore
In the result, all the appeals of the assessee are partly allowed for statistical purposes
ITA 1521/BANG/2019[2015-16]Status: DisposedITAT Bangalore27 Jan 2021AY 2015-16
Bench: Shri Chandra Poojari & Shri George George K.
For Appellant: Shri Prashanth Chandrashekar, CAFor Respondent: Shri Kannan Narayanan, Jt.CIT(DR)(ITAT), Bengaluru
Section 14Section 143(3)Section 148Section 37
…t in obtaining a benefit of enduring nature (sale orders) always and in many cases, the technical knowledge (repository) is important. The Ld. AR relied on the judgment of the Rajasthan High Court in the case of CIT vs. Rajasthan Spg. & Wvg. Mills Ltd. (2004) 137 Taxmann 249. The High Court held as follows: “16. From the aforesaid judgments of the Supreme Court, it is apparent that merely because the amount spent has been used for construction of a building or structure of permanent nature is not the decisive test for holding the expenses to be capital out-lay or revenue out-lay. The two tests emerging from the…