Tribunal grants partial appeal on interest & renovation expenses, remands for reassessment.

The Tribunal partially allowed the appellant's appeal regarding disallowance of interest on outstanding advances and renovation expenses as deferred revenue expenditure. The Tribunal directed the Assessing Officer to readjudicate these issues based on relevant precedents. However, the issue of restriction of depreciation on a car was not seriously contested and was treated as not pressed. Additionally, the Tribunal instructed the Assessing Officer to allow the deduction of consultancy charges based on a High Court decision. The Tribunal set aside previous orders and remanded the matters for reconsideration.

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Issues involved:
1. Disallowance of interest on outstanding advances
2. Disallowance of renovation expenses as deferred revenue expenditure
3. Restriction of depreciation on car
4. Disallowance of consultancy charges to International Caterers Pvt. Ltd.

Issue 1: Disallowance of interest on outstanding advances
The appellant contested the disallowance of interest on old outstanding advances, arguing that the advances were for business purposes. Both parties agreed to restore the matter to the Assessing Officer based on a similar issue in the previous year. The Tribunal set aside the orders and directed the Assessing Officer to readjudicate the issue.

Issue 2: Disallowance of renovation expenses as deferred revenue expenditure
The appellant claimed 1/10th of renovation expenses as deferred revenue expenditure, citing the principle of matching concept. The Tribunal noted the Revenue's inconsistent stance over the years and referred to a High Court decision allowing spreading over such expenses. The Tribunal set aside the previous orders and instructed the Assessing Officer to reevaluate the issue considering the High Court decision.

Issue 3: Restriction of depreciation on car
The appellant raised a discrepancy in the depreciation percentage allowed by the Assessing Officer. The Tribunal acknowledged the typographical error but found the issue not seriously contested by the appellant. Consequently, the ground was treated as not pressed.

Issue 4: Disallowance of consultancy charges to International Caterers Pvt. Ltd.
The Assessing Officer disallowed consultancy charges paid to a company, which was later challenged by the appellant. The Tribunal admitted an additional ground raised by the appellant and directed the Assessing Officer to allow the deduction based on a High Court decision. The Tribunal set aside the previous orders and instructed the Assessing Officer to reconsider the matter in light of the High Court decision.

In conclusion, the Tribunal partially allowed the appellant's appeal and allowed the Revenue's appeal for statistical purposes. The decision was pronounced in open court on 14th June 2013.

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