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Deputy Commissioner Of Income-Tax, ... vs Sulzer India Private Limited, Pune on 2 September, 2020
cites
Commissioner Of Income Tax V vs M/S.Rpg Transmission Ltd on 28 August, 2019
5. Respectfully following the decision of the Hon'ble Jurisdictional High
Court in the case of CIT Vs. M/s. KSB Pumps Ltd. (supra), we uphold the
impugned order of ld. CIT(Appeals) allowing the claim of assessee for
deduction on account of expenditure incurred on SAP implementation and
dismiss ground No.1.
C.I.T.,Ludhiana vs M/S.Varinder Agro Chemicals Ltd. on 7 July, 2015
138) and of the
Hon'ble Punjab & Haryana High Court in the case of CIT vs Varindra
Agro Chemical Ltd. (309 ITR 272) (P & H) contending that on the
similar facts of the case the expenditure was treated and allowed as
revenue expenditure, was also denied by the AO attempting to
distinguish the findings in the said cases in para 4, page nos. 2 & 3
of the assessment order which has also been quoted above.
Lotus Footwear Enterprises Limited - ... vs Dcit International Taxation 1(1) & ... on 22 January, 2019
5.3.1 The appellant, on the other hand, relying on the said decisions
and further a number of decisions during the appellate proceedings
contended that SAP package was to be used for business purpose
and that such expenditure had not resulted in bringing into existence
any new asset nor has any permanent or an enduring benefit accrued
to the appellant, which could be capital in nature. The appellant
further contended that such expenditure on the assets of the company
were necessary for the purpose of preserving and maintaining of
already existing assets and under no circumstances such expenditure
brought into existence any new asset nor did it give the Appellant any
new or different advantage or an enduring benefit. Further contended
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that such expenditure was not incurred by the appellant on "once and
for all basis" but for maintaining and preserving the assets of the
company on continuous basis for its effective and efficient day-to-day
working. The appellant reiterated that such expenditure was
necessary for the efficient functioning of the assets of the company
and hence was in the nature of revenue expenditure. The appellant
finally stated that under such condition, expenditure on SAP
implementation was wrongly treated by the AO as capital expenditure
and should be allowed as revenue expenditure. The appellant also
relied on the decision cited before the AO and further
the decision of the Special Bench of Delhi Tribunal in the case of
Amway India Enterprises v. DCIT (114 TTJ 476)(Del.) (SB).
Commissioner Of Income-Tax, Bombay ... vs Geoffrey Manners & Co. Ltd. on 28 March, 1976
12. Our attention was also drawn to the decision of this Court in
Commissioner of Income Tax Vs. Geoffrey Manners & Co., Ltd. 226
Taxman 135 wherein in the context of installation of software
programme, the Court inter alia has observed as under :
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