Tribunal held, that there was no infirmity in the action of the AO. The proceedings under S. 154 cannot be initiated on debatable issue but if the ultimate answer to the question which is a subject matter of the proceedings under S.154 can only be one then the proceedings under S.154 can be initiated and cannot be cancelled on the ground that the issue that was a subject matter of proceeding under S.154 were debatable involving a long drawn process of reasoning. The Supreme Court decision in Punjab State Industrial Development Corporation Ltd. v. CIT (1997) 225 ITR 792 (SC)  was available when the AO  passed the order of assessment, and it could not be said that there could be different views on the question whether fees paid to the Registrar of Companies on expansion of capital base was capital expenditure or revenue expenditure. (AY. 2014-15)