Held that capitalization of 70 per cent of expenditure was not due to matching concept as submitted by assessee but was due to fact that a French company acquired 70 per cent shares of assessee. Tribunal observed that the  expenditure having been allowed as revenue expenditure in earlier assessment years 2010-11 and 2011-12, same should be followed as per principle of consistency, was not acceptable as facts being different, decision taken by Assessing Officer in one assessment year would not constitute binding precedent in any subsequent assessment year. Expenditure is capital in nature and would be eligible for depreciation.  (AY. 2012-13 to 2016-17)