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The ITAT upheld the CIT(A)'s decision: the State sales-tax subsidy under the backward-area development scheme is a capital receipt not chargeable to tax and must be excluded from book profits for section 115JB (MAT); Revenue's appeal dismissed. Depreciation claimed on intangible assets and goodwill arising on amalgamation is allowed, with the established WDV to be carried forward and not reopened by the AO. Product-registration expenditures are allowable as revenue deductions under section 37(1). Deduction under section 80IA is allowable in principle, but the AO is directed to recompute eligible profits after excluding non-eligible income, setting off brought-forward losses and reasonably apportioning administrative/financial costs. Guarantee-commission addition restricted to 0.50% of guarantee value.
The ITAT upheld the CIT(A)'s decision: the State sales-tax subsidy under the backward-area development scheme is a capital receipt not chargeable to tax and must be excluded from book profits for section 115JB (MAT); Revenue's appeal dismissed. Depreciation claimed on intangible assets and goodwill arising on amalgamation is allowed, with the established WDV to be carried forward and not reopened by the AO. Product-registration expenditures are allowable as revenue deductions under section 37(1). Deduction under section 80IA is allowable in principle, but the AO is directed to recompute eligible profits after excluding non-eligible income, setting off brought-forward losses and reasonably apportioning administrative/financial costs. Guarantee-commission addition restricted to 0.50% of guarantee value.
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