2023 (10) TMI 515

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.... Khorana, Advs. For the Respondent : Mr Zoheb Hossain, Sr. Standing Counsel with Mr Sanjeev Menon, Jr Standing Counsel. ORDER RAJIV SHAKDHER, J.: 1. This appeal concerns Assessment Year (AY) 1993-94. Via the instant appeal, the appellant/assessee seeks to assail the order dated 28.04.2006 passed by the Income Tax Appellate Tribunal [in short, "Tribunal"] in ITA No.1157/Del/97 and ITA No.1129....

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....ishment" is capital expenditure?" 3. We have dealt with pari materia substantial questions of law while deciding ITA No.1398/2006, concerning AY 1992-93, which was treated as the lead matter with the consent of counsels for the parties. 4. We may note that the only difference that obtains in the questions of law framed in ITA No.1398/2006 concerns the quantum of fees paid to the consultant. 4.....

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....ning "repairs and renovation". The disallowance has been erroneously noted as Rs.3,64,11,475/- instead of Rs.3,64,11,478/-] and sustained the disallowance amounting to Rs. 11,24,124/- which was against conference room wall-panelling and writing board unit, board room and corridor wallpanelling on the 6th and 7th floors and lounge and corridor wall-panelling. 6. Insofar as the payment of fees to G....

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....id appeal will apply mutatis mutandis to the instant case as well: 9. The appellant/assessee will be entitled to claim the following deductions, as, in our opinion, they are in the nature of revenue expenditure: (i) Rs.3,64,11,478/- incurred on renovation, refurbishment and repairs. (ii) Rs.2,81,525/- incurred on payment of fees to GEL. 9.1 Insofar as the amount of Rs. 10,43,12,000/- is co....