Assessee company was engaged in business of manufacturing and sale of on road automobiles, agricultural tractor, implements, etc. Assessee incurred expenditure on account of payment for technical consultants for upgrading engines of vehicles so as to make emission normal and also to make vehicles eco-friendly. Tribunal held that said expenditure was to be treated as capital in nature and assessee was entitled to depreciation thereon. (AY. 2005-06)
Mahindra & Mahindra Ltd. v. ACIT (2020) 184 ITD 621 (Mum.) (Trib.)
S. 37(1) : Business expenditure-Capital or revenue-Technical know-how-For upgrading engines of vehicles so as to make emission normal and also to make vehicles eco-friendly-Capital in nature-Entitle depreciation. [S. 32]