Ajay Kumar Mittal, J. - (1.) This appeal has been preferred by the appellant -revenue under Sec. 260A of the Income Tax Act, 1961 (in short, "the Act") against the order dated 4.2.2015, Annexure A.III passed by the Income Tax Appellate Tribunal, Delhi Bench 'F' New Delhi (in short, "the Tribunal") in ITA No. 5223/DEL/2014 for the assessment year 2009 -10, claiming following substantial questions of law: - "1. Whether in the facts and circumstances of the case, the ITAT was correct in granting the relief of Rs. 88,85,332/ - by treating the expenditure incurred on procurement of research reports as revenue in nature?
(2.) Whether in the facts and circumstances of the case, the ITAT was correct in ignoring the fact that the research reports would have enduring benefits to the business of the assessee?
(3.) Whether in the facts and circumstances of the case, the ITAT was correct in ignoring the fact that the assessee company wanted to extend its operations and look for means for attracting potential customers and to venture into new markets - 2. A few facts relevant for the decision of the controversy involved as narrated in the appeal may be noticed. The respondent -assessee company was incorporated on 16.4.2003. Its business is to provide business advisory and related knowledge based services to diverse sectors across the globe. Return declaring income of Rs. 91,67,000/ - was filed by the assessee online on 26.9.2009 which was processed under Sec. 143(1) of the Act. The case was selected for scrutiny. Notice under Sec. 143(2) of the Act was issued to the assessee. Assessment was completed under Sec. 143(3) of the Act at an income of Rs. 1,80,85,330/ -. Addition of Rs. 88,85,332/ - was made by treating huge expenditure incurred on acquiring research reports from M/s. Zensar Technologies Limited for extension of assessee's business as capital expenditure. The assessee had claimed this expenditure as revenue expenditure in nature. The Assessing Officer vide order dated 26.11.2012, Annexure A.I. treated this expenditure as capital expenditure by holding that the assessee had incurred this expenditure for the purpose of extension of its business. It was also held that the expenditure had been incurred with a view to bring into existence an intangible asset in the form of research reports about the market which will result in advantage of enduring nature for the benefit of the business of the assessee in subsequent years. Aggrieved by the order, the assessee filed appeal before the Commissioner of Income Tax (Appeals) [CIT(A)]. Vide order dated 21.7.2014, Annexure A.II, the CIT(A) upheld the addition made by the Assessing Officer. Still not satisfied, the assessee filed appeal before the Tribunal. Vide order dated 4.2.2015, Annexure A.III, the Tribunal allowed the appeal relying upon the decision of the Delhi High Court in CIT vs. Priya Road Show Limited, : (2011) 332 ITR 594 (Del.) holding that the expenditure incurred in respect of same business is allowable as revenue expenditure even if it is for expansion of the business. Hence the instant appeal by the revenue. 3. We have heard learned counsel for the parties.;