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2020 (2) TMI 446

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....A Revenue by: Shri S. Tamil Selvam, JCIT ORDER PER SHRI N.V. VASUDEVAN, VICE PRESIDENT : This is an appeal filed by assessee against order dated 20-06-2019 passed by Ld. CIT(A), Bangalore relating to assessment year 2014-15. 2. The assessee is a company. During the relevant previous year the assessee paid fees to the Registrar of Company (ROC) of an amount of Rs. 5,03,000/- towards increase i....

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....he income assessed u/s 143(3) of the IT Act, 1961. 4. On appeal by the assessee the ld.CIT(A) confirmed the order of Assessing Officer. 5. Before us, the ld.Counsel for the assessee did not dispute the legal position that the expenditure in question was capital in nature, but only submitted that the issue was debatable and therefore, proceedings u/s 154 of the Act was not appropriate. 6. We hav....

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....e that if the ultimate answer to the question which is subject matter of the proceedings u/s 154 of the Act, can only be one, then the proceedings u/s 154 of the Act can be initiated and cannot be cancelled on the ground that the issue that was subject matter of proceeding u/s 154 of the Act were debatable involving long drawn process of reasoning. With the decision of the Hon'ble Supreme Ciourt i....