https://www.taxtmi.com/caselaws?id=312748 The Punjab and Haryana HC allowed the assessee's writ petition challenging reassessment proceedings under section 147 initiated after 4 years. The AO sought to treat software upgradation and development expenses as capital expenditure instead of revenue expenditure previously accepted. The HC held that reassessment cannot be initiated merely due to change of opinion after the AO had originally accepted the return treating such expenses as revenue. The expenditures were disclosed during original assessment and were rightly treated as revenue since they facilitated the assessee's advertising and marketing business. The HC set aside the reassessment proceedings on grounds of both delay and merits, deciding in favour of the assessee. en-us Thu, 13 Apr 2023 00:00:00 +0530 Tue, 05 Mar 2024 08:58:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312748 The Punjab and Haryana HC allowed the assessee's writ petition challenging reassessment proceedings under section 147 initiated after 4 years. The AO sought to treat software upgradation and development expenses as capital expenditure instead of revenue expenditure previously accepted. The HC held that reassessment cannot be initiated merely due to change of opinion after the AO had originally accepted the return treating such expenses as revenue. The expenditures were disclosed during original assessment and were rightly treated as revenue since they facilitated the assessee's advertising and marketing business. The HC set aside the reassessment proceedings on grounds of both delay and merits, deciding in favour of the assessee. Case-Laws Income Tax Thu, 13 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312748