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2021 (8) TMI 874

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..... year same expenses were allowed in the case of the assessee. On the other hand, Ld. DR did not have anything to controvert the arguments of the assessee. In our considered opinion principle of consistency applies and in such case addition cannot be made and we do not find any merit in the appeal filed by the revenue and we are of the opinion that CIT(A) has passed detailed and reasoned order and same does not required any kind of interference at our end. In the result, the appeal filed by the revenue is dismissed. Nature of receipt against termination of lease agreement - taxable under the head income from other sources or income from house property or not taxable as capital receipt - CIT(A) confirming the finding of the AO for treatin .....

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..... the addition of ₹ 4,33,06,842/- made by AO in respect of the Supervisory and Risk Management expenses. 2. The appellant craves, leave for reserving the right to amend, modify, alter, add or forego any ground(s) of appeal at any time before or during the hearing of this appeal. 2. This appeal has been preferred by the revenue against the order of the Ld. CIT(A) no. 392/2013-14 order dated 28th March, 2016 arising out of assessment order dated 23rd March, 2014. 3. Facts of the case are that the assessee is engaged in the business of insurance broker for life and non-life products of all insurance companies. The insurance broking activity is to assist clients to have the best quotation and best products from all life and .....

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..... capitalized or not and from the fact discussed, it is clear that expenditure is not required to be capitalized and held that finding of AO that the expenditure should be capitalized cannot be accepted and granted a relief to the assessee. 6. The Ld. AR stated that in preceding year and in succeeding year same expenses were allowed in the case of the assessee. On the other hand, Ld. DR did not have anything to controvert the arguments of the assessee. In our considered opinion principle of consistency applies and in such case addition cannot be made and we do not find any merit in the appeal filed by the revenue and we are of the opinion that Ld. CIT(A) has passed detailed and reasoned order and same does not required any kind of interfer .....

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