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2014 (9) TMI 938 - ITAT AHMEDABADValidity of reopening of assessment - issuance of notice of reopening u/s.147 by a successor officer on the basis of satisfaction recorded by his predecessor - Held that:- It is not disputed by the Revenue that in the earlier year the claim of the assessee was allowed under the scrutiny assessment. It is settled proposition of law that ordinarily, revenue expenditure which is incurred wholly and exclusively for the purpose of business must be allowed in its entirety in the year in which it is incurred. It cannot be spread over a number of years even if the assessee has written it off in his books over a period of years. However, the facts may justify an assessee who has incurred expenditure in a particular year to spread and claim it over a period of ensuing years. In fact, allowing the entire expenditure in one year might give a very distorted picture of the profits of a particular year. In the case in hand, the AO in the earlier years had examined as well in this year this aspect, therefore we are of the considered view that on this ground re-opening is not justified. - Decided against Revenue.
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