Held that the expenditure on repairs and maintenance was on replacement of parts of machinery and plant, which could not be treated at par with repairs and maintenance of the entire plant and machinery. The pipelines and dual fuel burner system formed a part of the entire plant and machinery, and these parts did not function independently. Allowable as expenses were of revenue nature. (AY. 2011-12)
Gujarat State Fertilizers and Chemicals Ltd. v. Dy. CIT (2024) 110 ITR 641 (Ahd)(Trib)
S. 31 : Repairs-Current repairs-Manufacture Of Fertilisers and chemicals-Expenditure on pipelines and fuel burner-Parts of plant and machinery-Parts incapable of independent use-Replacement of parts of machine is current repairs-Expenses allowable as revenue expenditure.[S.37(1)]
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