Expenditure incurred on the total reconditioning and overhauling of the machinery, which had outlived its utility, by replacing many vital parts in order to make the same functional cannot be treated as current repairs

Bharat Gears Limited Vs CIT High Court of Delhi ITA Nos. 14/2005, 1600 & 1670/2010 Decided on: 3 June 2011  Judgement A.K. Sikri, J. 1. In all these three appeals the assessee is the same and even the issue is identical, which pertains to three different assessment years, the factual premise on which such an issue has arisen for consideration is somewhat different. Therefore, we propose to first take up the facts of ITA No.14/2005 to understand and appreciate the question of law on which this appeal is admitted. ITA No. 14/2005 2. This appeal relates to assessment year 1994-95 and is fil...