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ITAT upheld the AO's disallowance of deductions claimed as "impairment of assets" and "abnormal loss" on spares, holding such amounts relate to depreciable fixed assets and are not allowable as revenue expenditure; the Tribunal directed the AO to permit adjustment of those amounts in the relevant block of assets and to allow consequent depreciation. Concurrently, ITAT quashed the penalty under section 270A for misreporting, finding no misrepresentation, suppression, false entry or unsupported claim, and noting absence of requisite findings by the AO; grounds challenging the disallowance were dismissed while the penalty was cancelled.
ITAT upheld the AO's disallowance of deductions claimed as "impairment of assets" and "abnormal loss" on spares, holding such amounts relate to depreciable fixed assets and are not allowable as revenue expenditure; the Tribunal directed the AO to permit adjustment of those amounts in the relevant block of assets and to allow consequent depreciation. Concurrently, ITAT quashed the penalty under section 270A for misreporting, finding no misrepresentation, suppression, false entry or unsupported claim, and noting absence of requisite findings by the AO; grounds challenging the disallowance were dismissed while the penalty was cancelled.
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