Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
HC allowed the assessee's appeal, determining that expenditures on leasehold property (including carpentry, electrical work, painting, false ceiling, repairs, maintenance, and miscellaneous expenses) constitute revenue expenditure. The court rejected the Tribunal's interpretation that simultaneous repair works amounted to reconstruction. The HC clarified that Explanation (1) to Section 32(1)(ii) enables lessees to claim depreciation and does not mandate treating all leasehold property expenses as capital expenditure. The court found the Tribunal's reasoning perverse and not supported by available evidence, thereby validating the assessee's claim of revenue expenditure.
HC allowed the assessee's appeal, determining that expenditures on leasehold property (including carpentry, electrical work, painting, false ceiling, repairs, maintenance, and miscellaneous expenses) constitute revenue expenditure. The court rejected the Tribunal's interpretation that simultaneous repair works amounted to reconstruction. The HC clarified that Explanation (1) to Section 32(1)(ii) enables lessees to claim depreciation and does not mandate treating all leasehold property expenses as capital expenditure. The court found the Tribunal's reasoning perverse and not supported by available evidence, thereby validating the assessee's claim of revenue expenditure.
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