Interest on customers' fixed deposits was held deductible...

Interest on customers' fixed deposits was held deductible because the taxpayer produced contemporaneous evidence of deposits and TDS, and mere absence of payee-side acknowledgement could not justify disallowance; deletion was sustained. Disallowance under s.14A r.w. Rule 8D was held inapplicable as the investments were maintained for SLR/CRR as stock-in-trade, following binding precedent; deletion was sustained. Depreciation on temporary wooden structures and software expenditure were treated as allowable (as per consistency with earlier years); disallowances were rejected. Inter-office adjustment provision was treated as an allowable anticipated liability supported by material, not a contingent/non-existent liability; disallowance was rejected. Deduction u/s 36(1)(viia) was directed to be allowed on total provision (rural and non-rural). Depreciation on G-Secs, HTM premium amortization loss, and provision for non-performing investments were allowed. - ITAT