9911796707
TMI Blog2015 (10) TMI 818X X X X Extracts X X X X X X X X Extracts X X X X ..... - ITAT allowed asessee's case - Held that:- Although a statement has been made in the memorandum of appeal that appeals are "learned to have been filed” in this Court by the Revenue in respect of the ITAT's orders for AYs 2003-04 and 2004-05, Mr N. P. Sahni, learned Senior Standing Counsel, candidly states that he has no details of any of those appeals having been listed before this Court after ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and of the Revenue that they should be treated as deferred revenue expenditure was not accepted by this Court. In its decision in CIT v. Citi Financial Consumer Finance Ltd. (2011 (3) TMI 622 - Delhi High Court) for AYs 2001-02, 2002-03, the Court held that "in the income-tax law, there is no concept of deferred revenue expenditure. Once the Assessee claims the deduction for the whole amount of su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fficer (AO) of a sum of ₹ 82,60,01,729/- pertaining to loan acquisition costs and ( b) disallowance by the AO of a sum of ₹ 70,19,637/- pertaining to expenditure incurred on the issue of non convertible debentures and commercial papers by considering it to be deferred revenue expenditure. 3. At the outset, Mr C. S. Aggarwal, learned Senior Counsel for the Assessee, has placed before t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... those appeals having been listed before this Court after having been numbered. The Court notes that the orders of the ITAT for AYs 2003-04, 2004-05 and 2005-06 were passed more than three years ago on 20th April, 2012. If since then any appeal had been filed with the Revenue and had been listed before the Court, it is unlikely that those details would not be available with either the Revenue or th ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
