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The ITAT upheld the CIT(A)'s decision disallowing the AO's addition of interest expenses, holding that since the assessee had commenced business operations, the interest expenditure qualifies as allowable revenue expenditure for the impugned year. Additions related to credit card payments and depreciation/amortization were deleted, as the expenses were duly accounted for by the subsidiary and appropriately adjusted in income computation. The Tribunal affirmed the CIT(A)'s jurisdiction to entertain the claim for deduction of premium on Non-Convertible Debentures raised for the first time on appeal, ruling such premium, being in the nature of interest, is an allowable revenue deduction. Regarding carry forward of losses, the AO was directed to reconsider the assessee's submissions, with no impact on tax liability. Grounds of appeal challenging these findings were dismissed accordingly.
The ITAT upheld the CIT(A)'s decision disallowing the AO's addition of interest expenses, holding that since the assessee had commenced business operations, the interest expenditure qualifies as allowable revenue expenditure for the impugned year. Additions related to credit card payments and depreciation/amortization were deleted, as the expenses were duly accounted for by the subsidiary and appropriately adjusted in income computation. The Tribunal affirmed the CIT(A)'s jurisdiction to entertain the claim for deduction of premium on Non-Convertible Debentures raised for the first time on appeal, ruling such premium, being in the nature of interest, is an allowable revenue deduction. Regarding carry forward of losses, the AO was directed to reconsider the assessee's submissions, with no impact on tax liability. Grounds of appeal challenging these findings were dismissed accordingly.
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