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ITAT allowed the assessee's appeals substantially. Following its own and HC/SC precedents in earlier AYs, ITAT held that each oil well is a separate undertaking eligible for deduction u/s 80IB(9), upheld depreciation on goodwill u/s 32, allowed higher depreciation @ 60% on oil wells/oil fields, and confirmed entitlement to additional depreciation u/s 32(1)(iia). The addition on account of ALP adjustment for HO expense allocation under the Production Sharing Contract was deleted, applying consistency with past accepted practice. Weighted deduction u/s 35(1)(ii) for payment to an ineligible research institution was disallowed. AO was directed to verify and grant MAT credit and full TDS credit as per Form 26AS, and to comply with DRP directions on deduction u/s 42 after fresh adjudication.
ITAT allowed the assessee's appeals substantially. Following its own and HC/SC precedents in earlier AYs, ITAT held that each oil well is a separate undertaking eligible for deduction u/s 80IB(9), upheld depreciation on goodwill u/s 32, allowed higher depreciation @ 60% on oil wells/oil fields, and confirmed entitlement to additional depreciation u/s 32(1)(iia). The addition on account of ALP adjustment for HO expense allocation under the Production Sharing Contract was deleted, applying consistency with past accepted practice. Weighted deduction u/s 35(1)(ii) for payment to an ineligible research institution was disallowed. AO was directed to verify and grant MAT credit and full TDS credit as per Form 26AS, and to comply with DRP directions on deduction u/s 42 after fresh adjudication.
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