Tribunal Decision: Disallowances addressed, some upheld, others deleted. Appeal partly allowed, interest deemed consequential.

The tribunal addressed multiple disallowances made by the AO, with some upheld and others deleted. The disallowance of wages expense was partly confirmed, disallowance of site expenses was deleted, disallowance of super structure cost was upheld, disallowance of lease rent was confirmed, and disallowance of letout property cost amortization was rejected. The tribunal allowed the appeal partly, with interest u/s 234D deemed consequential.

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Issues:
1. Disallowance of wages expense
2. Disallowance of site expenses
3. Disallowance of cost of super structure
4. Disallowance of lease rent
5. Disallowance of amortization of letout property cost
6. Interest u/s 234D

Analysis:
1. The first issue pertains to the disallowance of wages expense. The AO had made an adhoc disallowance, which was partly confirmed by the CIT (A). The tribunal declined to interfere with the CIT (A)'s decision as the assessee failed to provide a comparison chart of wages expenses percentage in the present and earlier years. Consequently, Ground No. 3 was rejected.

2. The second issue involved the disallowance of site expenses. The AO had disallowed a sum, which was reduced by the CIT (A). The tribunal, after considering the facts, found no justification for the disallowance and deleted the amount. Therefore, Ground No. 4 was allowed.

3. The third issue focused on the disallowance of the cost of super structure. The assessee claimed that a portion of the building used for business should be allowed as revenue expenditure. However, the tribunal held that since a major portion of the building was let out, the claim was not applicable. Therefore, Ground No. 5 was rejected.

4. The fourth issue concerned the disallowance of lease rent. The tribunal observed that there was no double disallowance as claimed by the assessee, and the AO's decision to disallow the lease rent was upheld. Hence, Ground No. 6 was rejected.

5. The fifth issue addressed the disallowance of amortization of the cost of the letout property. The tribunal referenced previous tribunal orders and held that the claim was not allowable under the relevant sections of the Income Tax Act. Consequently, Ground No. 7 was rejected.

6. The final issue related to interest u/s 234D, which was deemed consequential, and no further adjudication was required. The appeal was partly allowed by the tribunal.

In conclusion, the tribunal's judgment addressed various disallowances made by the AO, with some being upheld and others being deleted based on the facts and legal provisions. The detailed analysis of each issue provides clarity on the reasoning behind the tribunal's decisions.

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