Appeals partly allowed, issues remanded for fresh determination, decisions consistent with precedents .

The appeals were partly allowed, with certain issues being set aside to the AO for fresh determination and others being decided in favor of the assessee based on precedents and judicial pronouncements. The Tribunal's decisions were consistent with earlier rulings in the assessee's own case and relevant judicial precedents.

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Issues Involved:
1. Disallowance of depreciation on 'Management Rights'.
2. Disallowance of proportionate depreciation on additions to fixed assets.
3. Disallowance of interest on borrowings for acquisition of 100% share capital of a subsidiary.
4. Disallowance of interest on borrowings presumed to be used for interest-free loans.
5. Disallowance of interest on borrowings presumed to be used for non-business purposes.
6. Additions to book profit under section 115JB for provisions of doubtful debts, gratuity, and leave encashment.

Issue-wise Detailed Analysis:

1. Disallowance of Depreciation on 'Management Rights':
The assessee claimed depreciation on 'Management Rights' acquired during the year ending March 31, 2005, which was capitalized as intangibles. The AO disallowed this claim, considering it as a non-depreciable capital asset. The CIT(A) upheld this disallowance. The Tribunal, however, allowed the claim, citing the decision in the assessee's own case for earlier assessment years (2005-06 to 2007-08) where the Mumbai Tribunal allowed depreciation on management rights. The Tribunal also referenced the Supreme Court decision in Smifs Securities Ltd., which held that intangible assets in the form of goodwill are eligible for depreciation.

2. Disallowance of Proportionate Depreciation on Additions to Fixed Assets:
The AO disallowed depreciation at 60% on assets such as UPS, switches, and cables, treating them as non-computer items. The CIT(A) partially upheld the AO's decision, allowing 60% depreciation only on routers. The Tribunal set aside the issue back to the AO to review the list of fixed items and allow 60% depreciation on items integral to the computer system, otherwise, 15% depreciation for non-integral items.

3. Disallowance of Interest on Borrowings for Acquisition of 100% Share Capital of a Subsidiary:
The AO disallowed interest on borrowings used to acquire 100% share capital of Kanishka Housing Development Co. Ltd., considering it as non-business expenditure. The CIT(A) upheld this disallowance. The Tribunal set aside the issue back to the AO for fresh determination, following the decision in the assessee's own case for earlier assessment years, where the Tribunal restored the matter to the AO for deciding afresh as per law.

4. Disallowance of Interest on Borrowings Presumed to be Used for Interest-Free Loans:
The AO disallowed interest on borrowings presumed to be used for providing interest-free funds to Palanpur Holdings and Investments Pvt. Ltd. The CIT(A) upheld this disallowance. The Tribunal set aside the issue back to the AO for verification, directing the AO to decide the matter in light of the Bombay High Court decisions in Reliance Utilities and Power Ltd. and HDFC Bank Ltd., which held that if the assessee has sufficient own funds, the presumption is that investments are made from own funds.

5. Disallowance of Interest on Borrowings Presumed to be Used for Non-Business Purposes:
The AO disallowed interest on borrowings presumed to be used for investments in mutual funds. The CIT(A) upheld this disallowance. The Tribunal set aside the issue back to the AO for fresh determination, following the decision in the assessee's own case for earlier assessment years, where the Tribunal restored the matter to the AO for deciding afresh in terms of judicial pronouncements.

6. Additions to Book Profit under Section 115JB for Provisions of Doubtful Debts, Gratuity, and Leave Encashment:
The AO added provisions for doubtful debts, gratuity, and leave encashment to the book profit under section 115JB. The CIT(A) upheld these additions. The Tribunal upheld the addition for doubtful debts, citing the amendment to section 115JB by the Finance Act, 2009. However, for provisions for gratuity and leave encashment, the Tribunal allowed the assessee's claim, following the decision in the assessee's own case for earlier assessment years, where these were treated as ascertained liabilities not includible while computing book profit under section 115JB.

Conclusion:
The appeals were partly allowed, with certain issues being set aside to the AO for fresh determination and others being decided in favor of the assessee based on precedents and judicial pronouncements. The Tribunal's decisions were consistent with earlier rulings in the assessee's own case and relevant judicial precedents.

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