2010 (10) TMI 1053

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....f the assessee is directed against the order of the ld. CIT(A) dated 25.1.2000. The assessee is a Public Sector Undertaking and is engaged in the business of procurement of drugs, medicines and equipments and their distribution to various Government Hospitals on behalf of the Government of Tamilnadu and also running hi-tech diagnostic facilities at Government Hospitals. It was noticed that the appeal is time barred by 120 days for which a condonation petition supported by a duly attested affidavit of the competent authority has been filed. The reason mentioned is that during that period due to spread of chikungunya, the entire resources of the company were concentrating on the procurement and distribution of essential medical items for the ....

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....roving the infrastructural facilities at hospitals, improving the skills of the doctors and paramedical staff etc. But the Assessing Officer rejected the contention of the assessee and observed that even if no depreciation has been claimed by the assessee only, the items of such expenditure are not linked to the earning of income by of the company and the supply of equipments etc. to Government hospitals cannot be treated as sales promotion and hence, is not a revenue expenditure. The ld. CIT(A) has demonstrated the complete details of the customer care ledger account as on 31.03.1999 which has been reproduced in his order at pages 3 & 4, but at the end he has also sustained the addition of ₹ 29,54,125/- only by allowing ₹ 3 la....