Factory Shift ≠ Capital Asset – ITAT Allows ₹1.13 Cr as Revenue, Calls Out “Enduring Benefit” Overreach

NPR Auto Parts Manufacturing India Pvt. Ltd. Vs ITO (ITAT Bangalore) Factory Shift ≠ Capital Asset – ITAT Al-lows ₹1.13 Cr as Revenue, Calls Out “Enduring Benefit” Overreach In NPR Auto Parts Manufacturing India Pvt. Ltd., the Bangalore ITAT examined whether factory shifting expenses (₹1.13 crore) from rented premises to owned premises are capital or revenue in nature. The Assessing Officer and CIT(A) treated the ex-penses as capital, relying on the “enduring benefit” theory and decisions like Sitalpur Sugar Works. However, the ITAT disagreed and held: The assessee merely relo...