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Expenditure on power, fuel, and lease rent for hired machines held as capital expenditure incurred for establishing cement manufacturing unit at Bilaspur by ITAT, contrary to CIT(A) treating it as revenue expenditure. HC observed Revenue unable to state if appeal filed against Tribunal's order for AY 1984-85 on same issue. Principle of consistency applied based on Tribunal's order for AY 1984-85 in M/s. Raymond Woollen Mills Ltd. and HC orders for subsequent AYs. Referred Supreme Court's rulings in Godrej and Boyce Manufacturing Company Ltd. and Radhasoami Satsang reiterating need for consistency, certainty, and strong reasons for departure from settled position, which was absent. Assessee's appeal allowed.
Expenditure on power, fuel, and lease rent for hired machines held as capital expenditure incurred for establishing cement manufacturing unit at Bilaspur by ITAT, contrary to CIT(A) treating it as revenue expenditure. HC observed Revenue unable to state if appeal filed against Tribunal's order for AY 1984-85 on same issue. Principle of consistency applied based on Tribunal's order for AY 1984-85 in M/s. Raymond Woollen Mills Ltd. and HC orders for subsequent AYs. Referred Supreme Court's rulings in Godrej and Boyce Manufacturing Company Ltd. and Radhasoami Satsang reiterating need for consistency, certainty, and strong reasons for departure from settled position, which was absent. Assessee's appeal allowed.
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