TMI Blog2016 (9) TMI 1655X X X X Extracts X X X X X X X X Extracts X X X X ..... t for at least 2 or 3 years? - Tribunal deleting the addition treating the same as capital expenditure - HELD THAT:- As identical issue came up for consideration before this Court in case of this very assessee for earlier year [ 2016 (8) TMI 1462 - GUJARAT HIGH COURT ] attempt to contend that life of membrane would be spread over from 3 to 5 years or that the amount involved for replacement of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Shastri, JJ. Mr KM Parikh, Advocate for the Appellant Mr Manish J Shah, Caveator for the Opponent ORDER ( Per : Honourable Mr. Justice Akil Kureshi ) 1. The Revenue is in appeal against the judgement of the Income Tax Appellate Tribunal dated 17.12.2015 raising following questions for our consideration: 1. Whether on the facts and circumstances of the case, the Tribuna ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erent questions are framed, the issue is single viz. the correctness of the decision of the ITAT in deleting addition of ₹ 4.67 crores made on account of expenses incurred for replacement of remembering cells-II. The Revenue would contend that the expenditure is capital in nature and therefore, was not allowable deduction. 4. Both sides agreed that this issue in case of this very asses ..... X X X X Extracts X X X X X X X X Extracts X X X X
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