AO
disallowed expenditure incurred by the assessee on renovation of her hospital by
treating the same to be capital in nature. The Hon’ble ITAT observed that the
assessee was a doctor by profession and was having a hospital in rented
premises. Certain expenditure was incurred on renovation of the hospital for
attracting more customers and to remain in competition in the field of medical
profession. Such expenditure included colour, painting, repairs to terrace,
splitting the existing rooms, making attached bathrooms, replacement of
aluminium doors/windows for proper ventilation, etc. No new asset was created
by incurring such expenditure. Rather, it was a necessity for assessee’s
business to generate more profit by attracting more customers. Further, such
expenditure was also recurring in nature. It was held that any expenditure
which facilitated the assessee’s trading operations or enabling him to manage
and conduct his business more efficiently and profitably must be considered as
revenue expenditure. Accordingly, the impugned addition was deleted.
[DR.
PARUL ASHWIN SHAH Vs. ACIT – ITA 2072/Ahd/2012]
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