Film project write-off deduction allowed where abandoned production costs were treated as stock-in-trade and supported by prior Tribunal rulings.

Expenditure written off on an abandoned film project was held allowable as a deduction, following earlier coordinate bench decisions that treated expenditure on abandoned film production as deductible and recognised films in the hands of a film producer as stock-in-trade. The Tribunal rejected the Revenue's objection that a pending appeal against one earlier order was sufficient to deny the claim, holding that consistent jurisdictional Tribunal rulings supported allowance of the write-off. The Assessing Officer's disallowance was therefore deleted and the issue was decided in favour of the assessee.

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Issues: Whether the expenditure incurred on an abandoned film project, written off by the assessee, was allowable as a deduction.

Analysis: The Tribunal noted that the issue was already covered by earlier coordinate bench decisions treating expenditure on abandoned film production as allowable, and also recognising films in the hands of a film producer as stock-in-trade. It further observed that the Revenue's objection rested only on the fact that an appeal against one of the earlier Tribunal orders was pending, which by itself was not a valid basis to deny the claim when consistent jurisdictional Tribunal decisions had taken the same view.

Conclusion: The claim for write-off of expenditure on the abandoned film project was allowable, and the disallowance made by the Assessing Officer was rightly deleted; the issue was decided in favour of the assessee.

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