Debate on Nature of Expense- Penalty for disallowance unjustified

Piramal Healthcare Ltd. Vs DCIT (ITAT Mumbai) We find that the assessee had claimed business promotion expenses as revenue expenditure which was sought to be treated by the ld. AO as capital expenditure. This disallowance was ultimately sustained by the Tribunal in the quantum appellate proceedings. We find that the issue in dispute was whether the particular expenditure was capital or revenue in nature. Whether the particular expenditure is capital or revenue in nature would squarely fall within the ambit of debatable issue and the law is very well now settled that on a debatable issue, no pe...