Tribunal held that ;if original investment mainly consisting of building made for setting up of hotel is eligible for deduction then further investment in same infrastructure for purpose of expansion could not have been denied merely because substantial expansion did not involve setting up/instalment of plant and machinery. Accordingly the assessee engaged in running of a hotel in Himachal Pradesh under Eco-tourism project would be entitled to deduction on account of substantial expansion of unit. Referred , CIT v. Karnataka Power Corporation (2001) 247 ITR 268 (SC)(AY.2007-08, 2008-09, 2012-13 )
Sirmour Hotels (P.) Ltd. v. DCIT (2018) 170 ITD 318/193 TTJ 306/166 DTR 33 (Chd) (Trib.)
S. 80IC : Special category States -Hotel – Eco-tourism – Expansion of unit in hotel building constitutes investment in plant and machinery and entitle to deduction .