Tribunal upholds Assessee's claims, dismissing Revenue's appeal on various grounds. Consistency and High Court rulings emphasized.

The Tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s decisions on all grounds. The disallowance of expenses related to purchases, computation under Section 14A, depreciation treatment, deduction under Section 80IA, and TDS deduction were all ruled in favor of the Assessee. The Tribunal emphasized consistency, lack of new evidence, and adherence to jurisdictional High Court rulings in affirming the CIT(A)'s decisions.

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Issues Involved:
1. Disallowance of Rs. 15,55,200 on account of purchase from M/s. B.M. Sales Corporation.
2. Disallowance of Rs. 2,64,548 computed under Section 14A read with Rule 8D.
3. Depreciation on advertisement hoardings treated as temporary structures.
4. Deduction under Section 80IA for revenue from Foot Over-bridges and Bus Shelters.
5. TDS deduction under Section 194C vs. 194I for renting hoarding space.

Issue-wise Detailed Analysis:

1. Disallowance of Rs. 15,55,200 on account of purchase from M/s. B.M. Sales Corporation:
The Assessee, engaged in outdoor and media advertising, claimed to have purchased angles and channels worth Rs. 15,55,200 from M/s. B.M. Sales Corporation. The AO disallowed this expenditure, citing a previous assessment year (2009-10) where the purchase was deemed non-genuine based on M/s. B.M. Sales Corporation's denial of any transaction with the Assessee. The CIT(A) deleted the disallowance for the assessment year 2010-11, noting that no new facts were presented by the AO and the disallowance for 2009-10 was already deleted. The Tribunal upheld the CIT(A)'s decision, stating that the disallowance was based solely on the findings from the previous year, which had been overturned.

2. Disallowance of Rs. 2,64,548 computed under Section 14A read with Rule 8D:
The Assessee earned dividend income of Rs. 2,10,56,437, which is exempt from tax. The AO disallowed Rs. 11,31,387 under Rule 8D for expenses incurred in earning this exempt income, beyond the Rs. 8,66,839 already disallowed by the Assessee. The CIT(A) deleted the additional disallowance, noting the AO failed to provide material evidence that the Assessee's claim was incorrect. The Tribunal agreed, emphasizing that the AO must objectively reject the Assessee's claim before applying Rule 8D.

3. Depreciation on advertisement hoardings treated as temporary structures:
The Assessee claimed 100% depreciation on hoardings, which the AO disallowed, treating them as permanent structures eligible for only 15% depreciation. The CIT(A) allowed the Assessee's claim, referencing previous Tribunal decisions in favor of the Assessee. The Tribunal upheld this decision, citing consistency and lack of new evidence from the AO to substantiate a different view.

4. Deduction under Section 80IA for revenue from Foot Over-bridges and Bus Shelters:
The Assessee claimed a deduction of Rs. 1,74,42,469 under Section 80IA(4)(i) for revenue generated from advertisements on Foot Over-bridges and Road Medians. The AO disallowed this, arguing that such structures are not "roads" and citing a Supreme Court decision (Liberty India Ltd.) on the narrower interpretation of "derived from." The CIT(A) allowed the deduction, distinguishing the Assessee's case from Liberty India and emphasizing the direct nexus between the advertisement revenue and infrastructure development. The Tribunal upheld the CIT(A)'s decision, referencing consistent past rulings and rejecting new arguments not raised by the AO or CIT(A).

5. TDS deduction under Section 194C vs. 194I for renting hoarding space:
The Assessee deducted TDS at 2% under Section 194C for payments related to displaying advertisements on hoardings, while the AO argued that TDS should have been deducted at 10% under Section 194I, treating the payments as rent. The CIT(A) deleted the disallowance, following the Calcutta High Court's decision in M/s S.K. Tekriwal, which held that Section 40(a)(ia) applies only to non-deduction, not short deduction of TDS. The Tribunal upheld the CIT(A)'s decision, adhering to the jurisdictional High Court's binding precedent despite contrary views from other courts.

Conclusion:
The Tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s decisions on all grounds, emphasizing consistency, lack of new evidence, and adherence to jurisdictional High Court rulings.

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