Expenses on Electric Transformer treated as capital expenses. Installation costs not for personal benefit. Relief allowed to assessee.

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....The Appellate Tribunal addressed the issue of treating expenses on the installation of an Electric Transformer as capital expenses. It was established that the ownership of the transformer lies with the State Government or Electricity Company as per statutory provisions. The Tribunal noted that the transformer was installed at the project developed by the assessee and not for personal use. The CIT(A) determined that the expenses were covered by receipts from ultimate beneficiaries and did not provide enduring benefits to the assessee. As the ownership of the asset rested with the Electricity Board or distributor, the appeal of the revenue was dismissed.....