ITAT allowed the assessee's appeal substantially. The disallowance u/s 14A r.w.r. 8D was largely deleted, holding that AO failed to record the mandatory satisfaction u/s 14A(2), rendering application of Rule 8D jurisdictionally invalid; the assessee's suo motu disallowance was accepted, with Rule 8D(2)(i) and 8D(2)(ii) disallowances deleted, and Rule 8D(2)(iii) confined to investments actually yielding exempt income. Disallowances of professional fees to a group foundation and expenses of the UK branch/guest house were held revenue in nature and allowable u/s 37(1), including refurbishment expenses treated as repairs. However, payment for installation of a new pump system was held capital in nature, with depreciation allowable.
ITAT allowed the assessee's appeal substantially. The disallowance u/s 14A r.w.r. 8D was largely deleted, holding that AO failed to record the mandatory satisfaction u/s 14A(2), rendering application of Rule 8D jurisdictionally invalid; the assessee's suo motu disallowance was accepted, with Rule 8D(2)(i) and 8D(2)(ii) disallowances deleted, and Rule 8D(2)(iii) confined to investments actually yielding exempt income. Disallowances of professional fees to a group foundation and expenses of the UK branch/guest house were held revenue in nature and allowable u/s 37(1), including refurbishment expenses treated as repairs. However, payment for installation of a new pump system was held capital in nature, with depreciation allowable.
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