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The ITAT upheld the CIT(A)'s findings, rejecting the AO's proposed additions. The tribunal found no substantive evidence to disallow expenses related to management fees, infrastructure charges, and services for school operations. The corpus donation addition was dismissed due to lack of proof of improper benefit. Royalty payment to a specified entity was deemed legitimate, and the corporate guarantee charges were considered not sustainable under law. The depreciation disallowance was also set aside. Ultimately, the decision was rendered in favor of the assessee, with the revenue's contentions being comprehensively rejected across multiple grounds of challenge.
The ITAT upheld the CIT(A)'s findings, rejecting the AO's proposed additions. The tribunal found no substantive evidence to disallow expenses related to management fees, infrastructure charges, and services for school operations. The corpus donation addition was dismissed due to lack of proof of improper benefit. Royalty payment to a specified entity was deemed legitimate, and the corporate guarantee charges were considered not sustainable under law. The depreciation disallowance was also set aside. Ultimately, the decision was rendered in favor of the assessee, with the revenue's contentions being comprehensively rejected across multiple grounds of challenge.
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