2014 (9) TMI 361

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..... 41,14,537/-. The last revised return was taken up for scrutiny assessment and Assessment Order dated 18.12.2008 was passed by the Assessing Officer, disallowing expenditure of Rs. 42,60,293/- on the ground that it should be capitalized as it was "project work in progress". 3. The aforesaid finding was reversed by the Commissioner of Income Tax (Appeals) and the said order has been affirmed in favour of the respondent-assessee by the impugned order dated 06.12.2013 of the Income Tax Appellate Tribunal (ITAT). 4. Basic facts may be noticed. The respondent assessee was engaged in activity of providing consultancy services to Indian and foreign companies and with effect from 01.06.2004, they expanded into rendering venture capital advis....

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.... and stance of the respondent assessee was rejected. 5. The Commissioner of Income Tax (Appeals) accepted the plea and contention of the respondent-assessee, inter alia recording that at the time of finalization of accounts for the assessment year 2007-08, the assessee was advised to claim deduction of the expenditure in respective assessment years to which it pertained, since the same was in the nature of revenue expenditure incurred in the course of business and was allowable under Section 37 of the Act in accordance with the accepted principles of taxation. The revised return was filed in this year and similar expenditure was claimed in the income tax return filed for the assessment year 2007-08. The Commissioner of Income Tax (Appeal....