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I.C.SUDHIR, A.N.PAHUJA
Deputy Commissioner of Income-tax (LTU) – Appellant
Versus
Honda Siel Cars Ltd. – Respondent
A.N. Pahuja, Accountant Member - These cross appeals filed on 24.01.2012 by the Revenue and the corresponding cross-objection[CO] filed on 18.07.2012 by the assessee against an order dated 31.10.2011 of the ld. CIT(A)-LTU, New Delhi, raise the following grounds:-
I.T.A. No.1074/Del./2008[Revenue]
1. "On the facts and in the circumstances of the case and in law, the ld. CIT(A) has erred in deleting the addition of Rs. 1,09,23,694/- being aggregate amount of expenditure incurred as HIPACK-warranty Module HIPACK-Sales Modules and HIPACK-Parts Module.
2. On the facts and in the circumstances of the case, the ld. CIT(A) has erred in holding that the expenditure referred to in ground no.1 above is revenue expenditure.
3. The appellant craves leave to and add to alter, amend or vary from the above grounds of appeal at or before the time of hearing."
I.T.A. No.220/Del./2012[Assessee]
1. "That the CIT(A) erred on facts and in law in confirming the disallowance of Rs. 1,25,11,088/- made by the Assessing Officer, in respect of licence fee paid to Honda Motor Co. Japan(HMCL) for purchase of HIPACK Software Factory Module, Module, holding the same to be capital expenditure.
2. That the CIT(A)
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