ITAT dismissed the revenue's grounds challenging classification of expenditures on dies, moulds, jigs, fixtures and software as revenue in nature and allowable as deductions; penalty receipts from suppliers were held to be capital receipts and that ground was dismissed. The Tribunal directed deletion of impugned additions, upheld proportionate amortisation of non-refundable premium on 99-year leasehold land, and sustained prior-period charging of crystallised liabilities. Section 80IA deduction was allowed without adjustment for pre-assessment year depreciation and losses. Section 14A disallowance was deleted except administrative disallowance limited to 2% of exempt income. Transfer-pricing and doubtful-debts issues were remitted to AO/TPO for fresh consideration in accordance with law.
ITAT dismissed the revenue's grounds challenging classification of expenditures on dies, moulds, jigs, fixtures and software as revenue in nature and allowable as deductions; penalty receipts from suppliers were held to be capital receipts and that ground was dismissed. The Tribunal directed deletion of impugned additions, upheld proportionate amortisation of non-refundable premium on 99-year leasehold land, and sustained prior-period charging of crystallised liabilities. Section 80IA deduction was allowed without adjustment for pre-assessment year depreciation and losses. Section 14A disallowance was deleted except administrative disallowance limited to 2% of exempt income. Transfer-pricing and doubtful-debts issues were remitted to AO/TPO for fresh consideration in accordance with law.
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