Alternatively he submitted that if project completion method
adopted by the assessee company is not accepted, then the expenditure
should be allowed in the respective ... that the assessee was
capitalizing the expenditure in the earlier years, as it followed project
completion method, we find that
contingent and uncertain which
may or may not be discharged.
b) The method for calculation of provisions for
warranty is not based on actuarial valuation ... 2011 &
CO no. 35/Del./2011
scientific method which are acceptable methods
as per the decision of various courts.
c) The assessee could
submitted
that expenditure on addition to site office at Camp has been capitalized
by the assessee. Since this expenditure had not been claimed as revenue ... books have
been maintained. The books have been duly audited, percentage
completion method has been followed for accounting revenues on the
basis of the expenditure
2750/Del/2011
A.Y. 2007-08
disallowable expenditure by a reasonable method having
regard to the facts and circumstances which has not been
done ... fact that interest expenses on loans taken for
investment is already capitalized, in my view the amount
of Rs.68,385/- computed by the appellant
which contained detailed reasoning for making
the adjustment by application of CUP method and by determining ALP in
respect of following transactions at Nil:
Professional ... services
SAP consultancy charges and 26,893,871 Capitalized in fixed asset
other schedule.
Expenses
Total 56,157,877
3.1. The AO thereafter made
arrived, no further testing by applicability of another method is
envisaged by or is permissible as per law. We find that the above issue ... cause as to why the expenses claimed on royalty should not be
capitalized. Assessee submitted that royalty was in connection to using
knowhow to manufacture
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IN
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IN THE
