Following the ratio in Indus Motors Pvt Ltd v. Dy.CIT (2016) 382 ITR 503 (FB) (Ker)(HC), wherein the court held that whether the expenditure is capital or revenue has to be decided on the facts of the case applying the relevant tests. Appeal of the Revenue was dismissed. (AY. 2016-17)
ACIT v. PSN Automative Marketing (P) Ltd (2022) 100 ITR 69 (Cochin) (Trib)
S. 37(1) : Business expenditure-Capital or revenue expenditure-Temporary structure-100% depreciation is allowable.[S. 32]