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ITAT upheld CIT(A)'s decision allowing NHAI grant treatment as shareholder funds rather than asset cost reduction under section 43 Explanation (10) of I.T. Act, 1961. The grant constituted cash support for project viability and financial strength, not direct/indirect asset cost contribution, thus depreciation disallowance was inappropriate. However, ITAT reversed CIT(A) regarding periodic maintenance provisions, holding that under mercantile accounting, five-year accumulated maintenance expenses must be proportionately charged annually rather than entirely in the fifth year when repairs occur. The assessee's cross-appeal was dismissed as time-barred due to unexplained 1271-day delay, with ITAT finding insufficient reasonable cause despite assessee's participation in revenue's cross-appeal proceedings.
ITAT upheld CIT(A)'s decision allowing NHAI grant treatment as shareholder funds rather than asset cost reduction under section 43 Explanation (10) of I.T. Act, 1961. The grant constituted cash support for project viability and financial strength, not direct/indirect asset cost contribution, thus depreciation disallowance was inappropriate. However, ITAT reversed CIT(A) regarding periodic maintenance provisions, holding that under mercantile accounting, five-year accumulated maintenance expenses must be proportionately charged annually rather than entirely in the fifth year when repairs occur. The assessee's cross-appeal was dismissed as time-barred due to unexplained 1271-day delay, with ITAT finding insufficient reasonable cause despite assessee's participation in revenue's cross-appeal proceedings.
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