IT/ITES Project Management Fees Considered Capital Cost, Not Revenue Expenditure; Res Judicata Inapplicable in Tax Cases.

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....Nature of expenditure - Allowability of general management fees incurred when the assessee is still in the process of completing the project of IT/ITES project - the revenue expenditure incurred till the business is set-up should only add to the capital cost of the project. - The doctrine res-judicata has no application to the income-tax proceedings merely because the claim came to be in the earlier years, it is does not mean that the Assessing Officer should allow the same when he is conscious of the non-allowability of the claim in view of well settled position of law in this issue. - AT....