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of The key issue relates to the classification of the cost of silt as capital or revenue expenditure. The Assessing Officer (AO) treated it as capital expenditure and disallowed it, while the assessee claimed it as revenue expenditure. The assessee's contention is that the cost of filling pits with silt, a byproduct of stone extraction, is a recurring activity and hence a revenue expenditure. The CIT(A) agreed that the assessee utilized existing silt without purchasing new material, making it a revenue expenditure. The assessee valued the stock as per accepted trade practices and accounting standards, without any mala fide intention. Relying on relevant judicial precedents, the ITAT allowed the assessee's grounds, treating the cost of silt as revenue expenditure.
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