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The ITAT allowed the assessee's appeal, holding that the contribution to the Special Purpose Vehicle (SPV), mandated by the Supreme Court and administered by the Central Empowered Committee, qualifies as a business expenditure deductible under section 37(1). The payment, made to fund ameliorative and mitigative measures related to mining operations, was compulsory and directly linked to the continuation of the assessee's extraction and trading business. The tribunal distinguished the contribution from a penal imposition, noting the absence of discretion to challenge the payment and the uniform requirement imposed on all mining leaseholders regardless of irregularities. Consistent with prior decisions, the ITAT concluded the expenditure was wholly and exclusively incurred for business purposes, thereby reversing the Assessing Officer's disallowance.
The ITAT allowed the assessee's appeal, holding that the contribution to the Special Purpose Vehicle (SPV), mandated by the Supreme Court and administered by the Central Empowered Committee, qualifies as a business expenditure deductible under section 37(1). The payment, made to fund ameliorative and mitigative measures related to mining operations, was compulsory and directly linked to the continuation of the assessee's extraction and trading business. The tribunal distinguished the contribution from a penal imposition, noting the absence of discretion to challenge the payment and the uniform requirement imposed on all mining leaseholders regardless of irregularities. Consistent with prior decisions, the ITAT concluded the expenditure was wholly and exclusively incurred for business purposes, thereby reversing the Assessing Officer's disallowance.
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