ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE vs. SOFT TECH ENGINEERS PVT.LTD,, PUNE
In the result, Appeal of the Revenue is dismissed
ITA 2581/PUN/2017[2014-15]Status: DisposedITAT Pune22 Jul 2022AY 2014-15
Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.2581/Pun/2017 िनधा"रणवष" /Assessment Year: 2014-15 The Assistant Soft Tech Engineering Pvt. Ltd., Commissioner Of Income Vs Unit-5A, The Pentagon, Tax, Shahu College Road, Near Satara Circle-6, Pune. Road, Telephone Exchange, Pune – 411009. Pan: Aaccs 3857 L Appellant/ Revenue Respondent/ Assessee Assessee By Shri Nikhil Mutha – Ar Revenue By Shri S P Walimbe – Dr Date Of Hearing 06/06/2022 Date Of Pronouncement 22/07/2022 आदेश/ Order Per Dr.Dipak P.Ripote, Am: This Appeal Filed By The Revenue Is Directed Against The Order Of Ld.Commissioner Of Income-Tax(Appeals)-4, Pune’S Order Dated 30.05.2017 ,Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961, For The Assessment Year 2014-15. The Revenue Has Raised The Following Grounds Of Appeal: “1. On The Facts & In The Circumstances Of The Case, The Ld.Commissioner Of Income Tax(A) Has Erred In Allowing The Amount Of Rs.3,13,93,146/- Being Claim For Professional Fees & Contracting Expenses & Rs.61,03,239/- Being Managerial Expenses Relating To Software Development While The Same Should Be Capitalized & Not To Be Allowed As Revenue Expenses.
Section 143(2)Section 143(3)
section 143(3) on 07.12.2016
determining the income at Rs.7,50,33,345/- after making the following additions:
i)
Professional fees treated as Capital in nature
Rs.3,13,93,146/- ii) interest & Managerial Remuneration treated as Capital in nature
Rs. 61,03,239/- iii)
Disallowance