https://www.taxtmi.com/caselaws?id=236231 The court held that the reopening of assessment under Section 148 of the Income-tax Act, 1961 was invalid. The first ground regarding the treatment of SAP implementation charges as capital or revenue expenditure was found to be factually incorrect as the charges were capitalized. The second ground concerning the disallowance of proportionate expenditure for earning tax-free income was deemed impermissible as it amounted to a change of opinion. The court quashed the notice dated March 22, 2012, and disposed of the petition accordingly. en-us Mon, 29 Apr 2013 00:00:00 +0530 Fri, 31 Jan 2014 11:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236231 The court held that the reopening of assessment under Section 148 of the Income-tax Act, 1961 was invalid. The first ground regarding the treatment of SAP implementation charges as capital or revenue expenditure was found to be factually incorrect as the charges were capitalized. The second ground concerning the disallowance of proportionate expenditure for earning tax-free income was deemed impermissible as it amounted to a change of opinion. The court quashed the notice dated March 22, 2012, and disposed of the petition accordingly. Case-Laws Income Tax Mon, 29 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236231