2013 (12) TMI 637

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....has erred in deleting the addition of Rs. 3,68,31,000/- made on account of repair and maintenance.    ii) The appellant craves leave to add, alter or amend any ground of appeal raised above at the time of hearing. 3. In this case Assessing Officer observed that as per profit and loss account of the assessee there was an amount of Rs. 52,90,90,000/- debited under the head repairs and maintenance. Assessing Officer asked for the details. On verification of the details, Assessing Officer observed that the expenditures were not supported by the proper evidence in regard to roads repairs and maintenance of Rs. 4,09,24,000/- The Assessing Officer opined that expenditures were of enduring nature giving benefits for long terms. Furt....

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....enditure incurred on such repair and maintenance of approach roads of godowns is not incurred for creating any capital asset, but such expenditure has been incurred to preserve the existing roads for smooth conducting of operations. There are 1700 godowns spread all over India and the expenditure of Rs. 4.09 crore on repair and maintenance is reasonable. No enduring advantage has been derived by spending money on repair and maintenance of approach roads and such expenditure has been booked as revenue expenditure. During the course of appellate proceedings, the appellant has filed regional office wise expenditure on repair and maintenance of roads before me and such expenditure has been paid to the contractors for renovation of roads. The de....

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....st the above order the Revenue is in appeal before us. 6. We have heard the rival contentions in light of the material produced and precedent relied upon. We find that the assessee company is engaged in procurement, storage, movement and distribution of food grains. It is the assessee's contention that Corporation has got 1700 godowns which are connected with the roads for transporting food grains. These roads in godowns premises are connected with different shades and silos which are being used to preserve food grains. We note that the godowns roads are maintained every year to smooth movement of food grains. The expenditure incurred on such repair and maintenance of approach roads of godowns cannot be said to have resulted in any capit....