Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
The primary issue is classification of expenditure on railway track, conveyor belt and ventilation ducting as revenue or capital. The tribunal applied the enduring-benefit test: if expenditure creates an enduring asset for the business's permanent profit-earning apparatus it is capital; if it facilitates current contract operations and yields only temporary utility it is revenue. Applying this test, the tribunal found the site-specific railway siding, conveyor system and ventilation ducting were temporary, removable or functionally limited to the contract and did not enhance core capacity; accordingly the expenditure was revenue in nature and the appellant's appeal was allowed.
The primary issue is classification of expenditure on railway track, conveyor belt and ventilation ducting as revenue or capital. The tribunal applied the enduring-benefit test: if expenditure creates an enduring asset for the business's permanent profit-earning apparatus it is capital; if it facilitates current contract operations and yields only temporary utility it is revenue. Applying this test, the tribunal found the site-specific railway siding, conveyor system and ventilation ducting were temporary, removable or functionally limited to the contract and did not enhance core capacity; accordingly the expenditure was revenue in nature and the appellant's appeal was allowed.
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