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TMI Blog2021 (11) TMI 526X X X X Extracts X X X X X X X X Extracts X X X X ..... mar Aggarwal, Accountant Member 1. This appeal by assessee for Assessment Year [AY] 2015-16 arises out of the order of learned Commissioner of Income Tax (Appeals)-3, Chennai [CIT(A)] dated 25/04/2019 in the matter of assessment framed by Ld. Assessing Officer [AO] u/s. 143(3) of the Act on 27/12/2017. In this appeal, the grievance of the assessee is two-fold - (i) R & D expenditure treated as ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld not convince Ld. AO who treated the expenditure to be capital in nature. The Ld. CIT(A) upheld the stand of Ld. AO, inter-alia, by observing that the expenditure would bring enduring benefit to the assessee. Aggrieved, the assessee is in further appeal before us. 2.2. Upon perusal of impugned expenditure as placed on page no. 21 of the paper book, it could be seen that the expenditure is mostl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... precation granted by Ld. AO would stand reversed. The ground thus raised stand allowed. 3. Remuneration to Directors 3.1. The assessee paid remuneration of 12.00 Lacs each to four of its directors. Upon perusal of details and Form No. 16 as issued by the assessee to the directors, it transpired that the component of Rs. 12 Lacs include medical allowance and travel/expenditure reimbursement which ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 107 of paper-book). Upon perusal of the same, we find that the directors were reimbursed telephone expenses, petrol/other expenses which are duly reflected in pay-slip issued by the assessee. Further, there are no findings by lower authorities that these reimbursements were taxable. Nevertheless this fact would not jeopardize assessee's claim of expenditure u/s. 37(1) since the assessee has i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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