discontinued while the penalty may stay. The only other issue for consideration is whether the incentive/penalty should be levied on both demand charge ... passed in Petition No. 19 of 2005 (M) had decided to defer consideration of the issue, in so far as they are concerned the Commission
buys such goods for consideration paid or promised or partly paid or
partly promised, or under any system of deferred payment, when such ... services for consideration paid or promised, or partly paid
and partly promised, or under any system of deferred payment, when such
services are availed
also, deferred tax charge should be considered as different than income-tax paid or payable as the term income-tax paid and deferred tax charges ... each other. Likewise deferred tax charge cannot be kept at par with income tax paid/payable as both are quite deferent. Apart from above fact
services for a consideration which has been paid or promised
or partly paid and partly promised, or under any system of deferred payment and
includes ... services for consideration paid or promised, or partly paid and
partly promised, or under any system of deferred payment, when such services
are availed
books of account as deferred revenue expenditure.
2.1 The assessing officer treated the expenses in question as deferred revenue expenditure and allowed the same only ... under consideration;
(ii) The assessee-company itself has not debited the entire amount to the profit and loss account and suo motu deferred
treated as deferred income with the following observations:
i) In respect of Time Shares cost portion of the Time Share consideration viz., 45% is treated ... under consideration. Similar view was taken in the case of CIT v. Varghese Mani 252 ITR 735 (Ker).
15. The concept of deferred income
been
deferred over a period of 3 years as deferred revenue expenditure.
However, in its return, the assessee company has claimed the entire
expenditure incurred ... expenditure is deferred revenue expenditure.
One it is held as revenue expenditure, it has to be allowed
in the year under consideration in which
service for a consideration which has been paid or promised or partly paid and partly promised, or under any system of deferred payment and includes ... services for consideration paid or promised, or partly paid and partly promised, or under any system of deferred payment, when such services are availed
buys such goods for consideration paid or
promised or partly paid or partly promised, or
under any system of deferred
payment , when such ... services for consideration paid or promised, or partly paid and partly
promised, or under any system of
deferred payment, when such services are availed
services for a consideration which has been paid or promised or partly paid and partly promised, or under any system of deferred payment and includes ... services for consideration paid or promised or partly paid and partly promised, or under any system of deferred payment, when such services are availed