Sutlej Cotton Mills Ltd. v. CIT

116 ITR 1Supreme Court of India1979#177 most cited

What is Sutlej Cotton Mills Ltd. v. CIT authority for?

A gain arising from the cancellation of a forward exchange contract entered into for the acquisition of a capital asset constitutes a capital receipt. Income-tax liability for such transactions is determined by the specific provisions of the Income Tax Act, independent of the accounting treatment in the books of account.

409

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2007 to 2026.

Also referred to as

Sutlej Cotton Mills Ltd · 116 ITR 1 · capital receipt · foreign exchange gain · forward contract · capital asset · Section 43A · income tax liability · accounting treatment · capital gains

Sections most often in play

Section 14ASection 37(1)Section 115JBSection 143(3)Section 32Section 143(2)Section 142(1)Section 250
Read the full judgment

Issues it is cited on

section 43aeligible businessbook profitssection 115jsection 115jbrevenue expendituresection 80iamercantile system of accountingamalgamationsection 37(1)section 80isection 43

Judgments citing Sutlej Cotton Mills Ltd. v. CIT

Greatship (India ) Ltd, Mumbai vs. DCIT 5(1)(1), Mumbai

The appeal stand partly allowed

ITA 7151/MUM/2017[2013-14]Status: DisposedITAT Mumbai05 Oct 2021AY 2013-14

Bench: Hon’Ble Shri Pavan Kumar Gadale, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am (Hearing Through Video Conferencing Mode) आयकरअपील सं./ I.T.A. No.7151/Mum/2017 (धििाारण वर्ा / Assessment Year: 2013-14) Greatship (India) Ltd. Dcit-5(1)(1) बिाम/ Room No. 568, 5Th Floor, C/O Kalyaniwalla & Mistry Llp Esplande House, 29, Hazarimal Somani Marg Aaykar Bhavan, M. K. Road, Vs. Fort, Mumbai-400 001 Mumbai-400 020 स्थायीलेखासं./जीआइआरसं./ Pan/Gir No. Aabcg-8542-K (अपीलाथी/Appellant) : (प्रत्यथी / Respondent) अपीलाथीकीओरसे/ Appellant By : Ms. Ritu Kamal Kishore- Ld. Ar प्रत्यथीकीओरसे/Respondent By : Shri Sunil Deshpande- Ld. Sr. Dr सुनवाईकीतारीख/ : 31/08/2021 Date Of Hearing घोषणाकीतारीख / : 05/10/2021 Date Of Pronouncement आदेश / O R D E R Manoj Kumar Aggarwal (): - 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2013-14 Assails Final Assessment Order Dated 17/10/2017 Passed By Ld. Assessing Officer (Ao) U/S 143(3) R.W.S. 144C(13) Pursuant To The Directions Of Ld. Dispute Resolution Panel-I, Mumbai U/S 144C(5) Dated 28/09/2017. The Grounds Raised By The Assessee Read As Under: -

For Appellant: Ms. Ritu Kamal Kishore- Ld. ARFor Respondent: Shri Sunil Deshpande- Ld. Sr. DR
Section 133(6)Section 143(3)Section 144C(5)Section 14ASection 28Section 92BSection 92C

…assessee filed submissions and relied on the decision of Hon‟ble Bombay High Court in the case of Cadell Weaving Mills Company Private Ltd. V/s CIT (116 Taxman 77; 06/02/2001) as well as the decision of Hon‟ble Apex Court in Sutlej Cotton Mills Ltd. V/s CIT (116 ITR 1; 27/09/1978). 3.7 However, Ld. AO, relying upon the decision of Hon‟ble Bombay High Court in the case of Solid Containers Limited V/s DCIT (222 CTR 455; 29/08/2008) opined that the assessee advanced loans to its subsidiaries to spread its own business through subsidiaries and any profit yielded from such investments, whether by way of interest or e…

ACIT, Circle- 14(2), New Delhi vs. Kribhco Shyam Fertilizers Ltd., New Delhi

In the result, all appeals filed by the Revenue are dismissed

ITA 6100/DEL/2017[2014-15]Status: DisposedITAT Delhi30 Sept 2021AY 2014-15

Bench: Shri Kul Bharat & Dr.B.R.R.Kumar

Section 115J

…me is incurred on a capital asset or on fixed capital, such profit or loss would be of capital nature. This is settled judicial proposition as per the Supreme Court decision In the case of Sutlej 6 | P a g e ITA Nos.3489/Del/2017 & Others Cotton Mills Ltd. (116 ITR 1). As held by the Apex Court in number of decisions, the nature of any subsidy depends upon the purpose for which it was paid/received by the assessee and it is this "purpose test” that holds the key to decide whether any loss incurred subsequently on sale of the said Govt. bonds is capital or revenue in nature. The Supreme Court in the case of Ponn…

DCIT, New Delhi vs. M/S. Kribhco Shyam Fertilizers Ltd., New Delhi

In the result, all appeals filed by the Revenue are dismissed

ITA 3490/DEL/2017[2013-14]Status: DisposedITAT Delhi30 Sept 2021AY 2013-14

Bench: Shri Kul Bharat & Dr.B.R.R.Kumar

Section 115J

…me is incurred on a capital asset or on fixed capital, such profit or loss would be of capital nature. This is settled judicial proposition as per the Supreme Court decision In the case of Sutlej 6 | P a g e ITA Nos.3489/Del/2017 & Others Cotton Mills Ltd. (116 ITR 1). As held by the Apex Court in number of decisions, the nature of any subsidy depends upon the purpose for which it was paid/received by the assessee and it is this "purpose test” that holds the key to decide whether any loss incurred subsequently on sale of the said Govt. bonds is capital or revenue in nature. The Supreme Court in the case of Ponn…

DCIT, New Delhi vs. M/S. Kribhco Shyam Fertilizers Ltd., New Delhi

In the result, all appeals filed by the Revenue are dismissed

ITA 3489/DEL/2017[2012-13]Status: DisposedITAT Delhi30 Sept 2021AY 2012-13

Bench: Shri Kul Bharat & Dr.B.R.R.Kumar

Section 115J

…me is incurred on a capital asset or on fixed capital, such profit or loss would be of capital nature. This is settled judicial proposition as per the Supreme Court decision In the case of Sutlej 6 | P a g e ITA Nos.3489/Del/2017 & Others Cotton Mills Ltd. (116 ITR 1). As held by the Apex Court in number of decisions, the nature of any subsidy depends upon the purpose for which it was paid/received by the assessee and it is this "purpose test” that holds the key to decide whether any loss incurred subsequently on sale of the said Govt. bonds is capital or revenue in nature. The Supreme Court in the case of Ponn…

DCIT 10(1)(2), Mumbai vs. Kdd India P. Ltd, Mumbai

Appeal of the Revenue is dismissed being devoid of any merit

ITA 3408/MUM/2019[2014-15]Status: DisposedITAT Mumbai01 Sept 2021AY 2014-15

Bench: Shri Shamim Yahya & Shri Vikas Awasthyआ.अ. सं. 3408/मुं/2019 (िन.व. 2014-15)

For Appellant: Shri Gurbinder SinghFor Respondent: Shri Lalchand Choudhary
Section 143(3)Section 35DSection 37(1)

…examined on the touchstone of provisions contained in the Act [See - Kedarnath Jute Mfg. Co. Ltd. v. CIT [1971] 82 ITR 363 (SC); Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT [1997] 227 ITR 172/93 Taxman 502 (SC); Sutlej Cotton Mills Ltd. v. CIT [1979] 116 ITR 1 (SC) and United Commercial Bank v. CIT [1999] 240 ITR 355/106 Taxman 601 (SC). 20. At the most, an inference can be drawn that by showing this expenditure in a spread over manner in the books of account, the assessee had initially intended to make such an option. However, it abandoned the same before reaching the crucial stage, inasmuch as, in the…

ACIT, Circle- 5(1), New Delhi vs. Bumi Hiway (India) Ltd., New Delhi

In the result, all the appeals of the Revenue and assessee and cross objection of the assessee are allowed for the statistical purposes

ITA 601/DEL/2018[2013-14]Status: DisposedITAT Delhi10 Aug 2021AY 2013-14

Bench: Shri O.P. Kant & Shri Kuldip Singh[Through Video Conferencing] Assessment Year: 2012-13

…of the question whether the assessee has earned any profit or suffered any loss; what does need to be considered is the true nature of the transaction and whether in fact it has resulted in profit or loss to the assessee [Sutlej Cotton Mills Ltd Vs CIT (1979) 116 ITR 1 (SC)]. vii. Even an unrealized loss on an interest rate swap transaction has been allowed as a deduction as the assessee had 6 ITA No. 600 & 601/Del/2018; C.O. No. 77 & 78/Del/2018; consistently followed the same method of accounting as mandated by the RBI guidelines (JP Morgan Chase Bank Vs ADIT (2010) 42 SOT 30 (MUM) (URO). viii. In a case, where…

ACIT, Circle- 5(1), New Delhi vs. Bumi Hiway (India) Ltd., New Delhi

In the result, all the appeals of the Revenue and assessee and cross objection of the assessee are allowed for the statistical purposes

ITA 600/DEL/2018[2012-13]Status: DisposedITAT Delhi10 Aug 2021AY 2012-13

Bench: Shri O.P. Kant & Shri Kuldip Singh[Through Video Conferencing] Assessment Year: 2012-13

…of the question whether the assessee has earned any profit or suffered any loss; what does need to be considered is the true nature of the transaction and whether in fact it has resulted in profit or loss to the assessee [Sutlej Cotton Mills Ltd Vs CIT (1979) 116 ITR 1 (SC)]. vii. Even an unrealized loss on an interest rate swap transaction has been allowed as a deduction as the assessee had 6 ITA No. 600 & 601/Del/2018; C.O. No. 77 & 78/Del/2018; consistently followed the same method of accounting as mandated by the RBI guidelines (JP Morgan Chase Bank Vs ADIT (2010) 42 SOT 30 (MUM) (URO). viii. In a case, where…

Bumi Hiway (India) P.Ltd, New Delhi vs. DCIT, Circle-5(1), New Delhi

In the result, all the appeals of the Revenue and assessee and cross objection of the assessee are allowed for the statistical purposes

ITA 488/DEL/2018[2012-13]Status: DisposedITAT Delhi10 Aug 2021AY 2012-13

Bench: Shri O.P. Kant & Shri Kuldip Singh[Through Video Conferencing] Assessment Year: 2012-13

…of the question whether the assessee has earned any profit or suffered any loss; what does need to be considered is the true nature of the transaction and whether in fact it has resulted in profit or loss to the assessee [Sutlej Cotton Mills Ltd Vs CIT (1979) 116 ITR 1 (SC)]. vii. Even an unrealized loss on an interest rate swap transaction has been allowed as a deduction as the assessee had 6 ITA No. 600 & 601/Del/2018; C.O. No. 77 & 78/Del/2018; consistently followed the same method of accounting as mandated by the RBI guidelines (JP Morgan Chase Bank Vs ADIT (2010) 42 SOT 30 (MUM) (URO). viii. In a case, where…

Technologies Ltd) vs. ACIT

Appeals are allowed

ITA/214/2020HC Delhi05 Jul 2021
For Appellant: -.................................................................... 8For Respondent: - .................................................................. 10
Section 10BSection 143(3)Section 14ASection 254Section 35D

…mined on the touchstone of provisions contained in the Act [See - Kedarnath Jute Mfg. Co. Ltd. v. CIT [1971] 82 ITR 363 (SC); Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT [1997] 227 ITR 172/93 Taxman 502 (SC); Sutlej Cotton Mills Ltd. v. CIT [1979] 116 ITR 1 (SC) and United Commercial Bank v. CIT [1999] 240 ITR 355/106 Taxman 601 (SC). 20. At the most, an inference can be drawn that by showing this expenditure in a spread over manner in the books of account, the assessee had initially intended to make such an option. However, it abandoned the same before reaching the crucial stage, inasmuch as, in…

Technologies Ltd) vs. ACIT

Appeals are allowed

ITA/215/2020HC Delhi05 Jul 2021
For Appellant: -.................................................................... 8For Respondent: - .................................................................. 10
Section 10BSection 143(3)Section 14ASection 254Section 35D

…mined on the touchstone of provisions contained in the Act [See - Kedarnath Jute Mfg. Co. Ltd. v. CIT [1971] 82 ITR 363 (SC); Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT [1997] 227 ITR 172/93 Taxman 502 (SC); Sutlej Cotton Mills Ltd. v. CIT [1979] 116 ITR 1 (SC) and United Commercial Bank v. CIT [1999] 240 ITR 355/106 Taxman 601 (SC). 20. At the most, an inference can be drawn that by showing this expenditure in a spread over manner in the books of account, the assessee had initially intended to make such an option. However, it abandoned the same before reaching the crucial stage, inasmuch as, in…

Technologies Ltd) vs. ACIT

Appeals are allowed

ITA/213/2020HC Delhi05 Jul 2021
For Appellant: -.................................................................... 8For Respondent: - .................................................................. 10
Section 10BSection 143(3)Section 14ASection 254Section 35D

…mined on the touchstone of provisions contained in the Act [See - Kedarnath Jute Mfg. Co. Ltd. v. CIT [1971] 82 ITR 363 (SC); Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT [1997] 227 ITR 172/93 Taxman 502 (SC); Sutlej Cotton Mills Ltd. v. CIT [1979] 116 ITR 1 (SC) and United Commercial Bank v. CIT [1999] 240 ITR 355/106 Taxman 601 (SC). 20. At the most, an inference can be drawn that by showing this expenditure in a spread over manner in the books of account, the assessee had initially intended to make such an option. However, it abandoned the same before reaching the crucial stage, inasmuch as, in…

The Deputy Commissioner of Income Tax, Circle-1(1)(2), Surat vs. M/S. Garden Silk Mills Ltd., Surat

In the result, appeal of Revenue is dismissed

ITA 1209/AHD/2017[2012-13]Status: DisposedITAT Surat18 Jun 2021AY 2012-13

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) The Dy. Cit, Circle-1(1)(2), M/S Garden Silk Mills Ltd. Room No. 114, 1St Floor, Tulsi Krupa Araade, Vs Aayakar Bhavan, Near Aai Mata Chowk, Majuragate, Surat – 395010. Surat-395001. Pan : Aaacg8932C Assessee/ Appellant Revenue/Respondent

Section 143(3)Section 254(1)

…m abroad against foreign currency loan. Further, in order to safe guard its interest against the fluctuation in foreign currency entered into forward contract. The ld CIT(A) after relying on the decision of Hon’ble Supreme Court in Sutlej Cotton Mills Vs CIT (116 ITR 1 SC) held that if the amount in foreign currency was a trading asset then foreign exchange fluctuation would be a revenue expenses, but if held as capital account, the loss would be a capital loss. The ld CIT(A) also held that the decision in assessee’s own case for AY 1993-94 is also squarely applicable on this issue for the year under consideratio…

DCIT, Bangalore vs. M/S Cisco Systems India Pvt. Ltd., Bangalore

In the result, the Revenue’s appeal as well as Assessee’s appeal are partly allowed for statistical purposes

ITA 508/BANG/2015[2010-11]Status: DisposedITAT Bangalore15 Apr 2021AY 2010-11
For Appellant: Sri.Rajan Vora, CAFor Respondent: Sri.Muzafar Hussain, CIT-DR
Section 10ASection 143(3)Section 144CSection 144C(5)

…as capital has been provided in below. It is to be noted that of the Exchange gain of Rs.14,40,32,302 on restatement of creditors for fixed assets are not taxable in view of the decisions of Supreme Court decision in case of Sutlej Cotton Mills Ltd. vs. CIT (116 ITR 1) and Bombay HC decision in case of V.S. Dempo & Co Pvt. Ltd (206 ITR 291), which has specifically held that gain/ loss on arising on fixed capital on account of alteration in exchange rate is capital in nature. Further, in connection with foreign exchange gain of Rs.25,26,39,693 incurred on share application money, it is submitted that same is capi…

Cisco Systems (India) Private Limited, Bangalore vs. Asst.C.I.T., Bangalore

In the result, the Revenue’s appeal as well as Assessee’s appeal are partly allowed for statistical purposes

ITA 505/BANG/2015[2010-11]Status: DisposedITAT Bangalore14 Apr 2021AY 2010-11
For Appellant: Sri.Rajan Vora, CAFor Respondent: Sri.Muzafar Hussain, CIT-DR
Section 10ASection 143(3)Section 144CSection 144C(5)

…as capital has been provided in below. It is to be noted that of the Exchange gain of Rs.14,40,32,302 on restatement of creditors for fixed assets are not taxable in view of the decisions of Supreme Court decision in case of Sutlej Cotton Mills Ltd. vs. CIT (116 ITR 1) and Bombay HC decision in case of V.S. Dempo & Co Pvt. Ltd (206 ITR 291), which has specifically held that gain/ loss on arising on fixed capital on account of alteration in exchange rate is capital in nature. Further, in connection with foreign exchange gain of Rs.25,26,39,693 incurred on share application money, it is submitted that same is capi…

M/S. Dabur India Ltd., New Delhi vs. Addl.CIT, New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 6525/DEL/2014[2008-09]Status: DisposedITAT Delhi18 Feb 2021AY 2008-09

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Anupam Kant Garg, CIT-DR
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 80GSection 80ISection 92CSection 92E

…made in the books of account are not determinative of the ambit of taxation. If an item of per the provisions of the Act and not as per books of account:- i) Kedarnath Jute Manufacturing Company vs. CIT, 82 ITR 363 (SC); ii) Sutlej Cotton Mills Ltd. vs. CIT, 116 ITR 1 (SC); iii) Bharat Carbon and Ribbon Mfg. Co. (P) Ltd. vs. CIT, 239 ITR 505 (SC); iv) CIT vs. UP Electronics Corporation Ltd., 282 ITR 470 (All) 114.6 We have considered the rival arguments made by both the sides, perused the orders of the AO and the CIT(A) and the paper book filed on behalf of the assessee. We have also considered the various deci…

DCIT, New Delhi vs. M/S. Dabur India Ltd., New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 6256/DEL/2014[2008-09]Status: DisposedITAT Delhi18 Feb 2021AY 2008-09

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Anupam Kant Garg, CIT-DR
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 80GSection 80ISection 92CSection 92E

…made in the books of account are not determinative of the ambit of taxation. If an item of per the provisions of the Act and not as per books of account:- i) Kedarnath Jute Manufacturing Company vs. CIT, 82 ITR 363 (SC); ii) Sutlej Cotton Mills Ltd. vs. CIT, 116 ITR 1 (SC); iii) Bharat Carbon and Ribbon Mfg. Co. (P) Ltd. vs. CIT, 239 ITR 505 (SC); iv) CIT vs. UP Electronics Corporation Ltd., 282 ITR 470 (All) 114.6 We have considered the rival arguments made by both the sides, perused the orders of the AO and the CIT(A) and the paper book filed on behalf of the assessee. We have also considered the various deci…

M/S. Dabur India Ltd., New Delhi vs. Addl.CIT, New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 3241/DEL/2014[2007-08]Status: DisposedITAT Delhi18 Feb 2021AY 2007-08

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Anupam Kant Garg, CIT-DR
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 80GSection 80ISection 92CSection 92E

…made in the books of account are not determinative of the ambit of taxation. If an item of per the provisions of the Act and not as per books of account:- i) Kedarnath Jute Manufacturing Company vs. CIT, 82 ITR 363 (SC); ii) Sutlej Cotton Mills Ltd. vs. CIT, 116 ITR 1 (SC); iii) Bharat Carbon and Ribbon Mfg. Co. (P) Ltd. vs. CIT, 239 ITR 505 (SC); iv) CIT vs. UP Electronics Corporation Ltd., 282 ITR 470 (All) 114.6 We have considered the rival arguments made by both the sides, perused the orders of the AO and the CIT(A) and the paper book filed on behalf of the assessee. We have also considered the various deci…

DCIT, New Delhi vs. M/S. Dabur India Ltd., New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 3114/DEL/2014[2007-08]Status: DisposedITAT Delhi18 Feb 2021AY 2007-08

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Anupam Kant Garg, CIT-DR
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 80GSection 80ISection 92CSection 92E

…made in the books of account are not determinative of the ambit of taxation. If an item of per the provisions of the Act and not as per books of account:- i) Kedarnath Jute Manufacturing Company vs. CIT, 82 ITR 363 (SC); ii) Sutlej Cotton Mills Ltd. vs. CIT, 116 ITR 1 (SC); iii) Bharat Carbon and Ribbon Mfg. Co. (P) Ltd. vs. CIT, 239 ITR 505 (SC); iv) CIT vs. UP Electronics Corporation Ltd., 282 ITR 470 (All) 114.6 We have considered the rival arguments made by both the sides, perused the orders of the AO and the CIT(A) and the paper book filed on behalf of the assessee. We have also considered the various deci…

Smt. Nisha Jain, Kota vs. DCIT, Central Circle, Kota

In the result, the ground of appeal is allowed for statistical purposes

ITA 1368/JPR/2019[2016-17]Status: DisposedITAT Jaipur03 Feb 2021AY 2016-17
For Appellant: Shri P.C. ParwalFor Respondent: Smt. Runi Pal (ACIT) a

…is a settled law that making of accounting entries in the books of accounts is not relevant for determination of income under the Income Tax Act as held by Supreme Court in case ofKedarnath Jute Manufacturing Co. Ltd. 82 ITR 363 and Satluj Cotton Mills Vs CIT 116 ITR 1. 12. Per contra, the ld. DR relied upon the order of ld. CIT(A) which reads as under:- “7.3.1 The contention in appeal is that the assessee had billed Bhagat Public School Rs.48,18,961/- for advertisement charges and considered these bills in turnover. Subsequently, the order was not implemented so the effect of reduction of such sales, relevant co…

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

…mined on the touchstone of provisions contained in the Act (See – Kedarnath Jute Mfg. Co. Ltd. vs. CIT (1971) 82 ITR 363 (SC); Tuticorin Alkali Chemicals & Fertilizers Ltd. vs. CIT (1997) 227 ITR 172/93 Taxman 502 (SC); Sutlej Cotton Mills Ltd. vs. CIT (1979) 116 ITR 1 (SC) and United Commercial Bank vs. CIT (1999) 240 ITR 355/106 Taxman 601 (SC).” 23. The Ld. AR submitted that the CIT(A)’s observation that the Tribunal in assessee’s own case wrongly proceeded to bifurcate and split the expenses incurred by the assessee into Revenue and Capital, is not proper as the entire expenditure was incurred for a specific…