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The ITAT set aside the impugned assessments for de novo adjudication by the AO on grounds of failure of natural justice and inadequate inquiry, directing fresh consideration of evidence and invocation of section 131/133(6) where necessary; grounds 5 and 6 were allowed for statistical purposes. The Tribunal held that applicability of sections 43CA and 50C to depreciable/block assets requires fresh factual and legal examination. The disallowance under ESOP was deleted as an allowable business expenditure under section 37(1). Interest on NPAs is to be taxed in accordance with section 43D and RBI prudential norms. Broken period interest and provision for standard assets under section 36(1)(viia) were upheld as allowable.
The ITAT set aside the impugned assessments for de novo adjudication by the AO on grounds of failure of natural justice and inadequate inquiry, directing fresh consideration of evidence and invocation of section 131/133(6) where necessary; grounds 5 and 6 were allowed for statistical purposes. The Tribunal held that applicability of sections 43CA and 50C to depreciable/block assets requires fresh factual and legal examination. The disallowance under ESOP was deleted as an allowable business expenditure under section 37(1). Interest on NPAs is to be taxed in accordance with section 43D and RBI prudential norms. Broken period interest and provision for standard assets under section 36(1)(viia) were upheld as allowable.
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