Held that the expenditure incurred on rented premises cannot be treated as revenue in view of the plain provisions of Explanation 1 to Sec.32 of the Act. The ld.CIT(A) is in total ignorance of the provisions of Explanation 1 of Sec.32 of the Act held it to be revenue in nature. The decision relied upon by the learned counsel has no application after insertion of Explanation 1 of Sec.32 of the Act. Accordingly the order of ld.CIT(A) reversed and order of the Assessing Officer is affirmed. (AY. 2010-11, 2011-12)
Dy. CIT v. Atlas Copco (India) Ltd (No.1) (2022) 96 ITR 520 (Pune)(Trib) Dy. CIT v. Atlas Copco (India) Ltd (No.2) (2022) 96 ITR 566 (Pune)(Trib)
S. 37(1) : Business expenditure-Capital or revenue-Expenditure on rented premises-Not allowable as revenue expenditure. [S. 32]