B & A Digi Tactical Solutions Private ... vs Dcit, Chennai on 28 August, 2017
incurred was revenue in nature and not capital in nature. According to
him, Explanation 1 to Sec. 32 of the Income Tax Act, 1961 (in short
''the Act'') could be applied only where the expenditure incurred in
leasehold items was capital in nature. Alternatively according to him,
even if it was considered as capital expenditure it was only for a
temporary structure eligible for 100% depreciation. Reliance was
placed on the decision of Co-ordinate bench in the cases of M/s. Amec
Foster Wheeler India Pvt Ltd vs. DCIT in ITA No.1530/Mds/2016,
dated 25.11.2016 that of M/s. Cholamandalam Distribution Services
Ltd. vs. ACIT in ITA Nos.1952 & 1953/Mds/2016, dated 05.10.2016
and that of M/s. Cadensworth (India) Ltd vs. ACIT in 2838/Mds/2016,
dated 25.01.2017.