9911796707
TMI Blog2017 (8) TMI 1536X X X X Extracts X X X X X X X X Extracts X X X X ..... oyal, Advocate ORDER C.M. Nos. 22528/2017 (delay in filing) & 22529/2017 (delay in re-filing) 1. For the reasons stated in the applications, the delay in filing as well as re-filing is condoned and the applications are disposed of. ITA No. 480/2017 2. This is an appeal by the Revenue against the order dated 29th June, 2016 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA No. 3229/D ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unt of disallowance of entry tax, which was claimed as a deductible U/s 43B? 2.4. Whether Id. ITAT/CIT(A) erred in deleting the addition of Rs. 1,07,12,0631- made by the Assessing officer treating the expenditure incurred on software expenses as capital expenditure instead of revenue expenditure?". 3. Of the above four questions, according to the learned counsel for the Revenue, Question Nos. 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 312/2015 (CIT v. Honda SIEL Power Products Ltd.). This, in turn, refers to a decision in CIT v. Hero Motocorp Ltd., [2015] 372 ITR 481. The contention of the Assessee is that the agreement under which payment of royalty and lumpsum fee was made in the present case is identical to the agreement in those cases. 7. This is, however, disputed by the counsel for the Revenue. According to him, the sam ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
