SI Group India P. Ltd. v. ACIT (LTU) (2023)101 ITR 70 (SN)(Mum) (Trib)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Capital or Revenue expenditure-Consumables revenue expenditure allowable in the year in which put in line of production-Allowance in previous years not erroneous-Assessing Officer taking sustainable view after enquiry-Revision is not warranted. [S. 32, 37(1)]

Held, that an identical view had been taken by the A.O. after detailed examination in earlier years and the view taken by the A.O. was not found to be erroneous. When the judicial precedents were in favour of the assessee that consumables are revenue expenditure and were allowed to the assessee as deduction in the year in which those are put in line of production and no judicial precedent was shown to the effect that consumables were capital expenditure and not allowable in the year of use in production line, the view taken by the A.O. was a plausible and sustainable view. Thus, revision was not warranted. (AY. 2009-10, 2010-11)