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Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mine-closure deductions sustained.
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Disallowance of expenditure relating to investments yielding exempt income was confined to expenditure attributable to those investments, and the Tribunal upheld CIT(A)'s deletion of the AO's broader Rule 8D disallowance. Recomputation of the written down value of the civil-work block for windmills was permitted where past assessments had restricted depreciation, and consequential additional depreciation was directed to be allowed under the depreciation provisions. Provision for mine closure computed in accordance with Ministry guidelines on a scientific basis was held deductible as business expenditure under general deductibility principles, and the CIT(A)'s allowance of that provision was sustained; revenue appeal dismissed.
Disallowance of expenditure relating to investments yielding exempt income was confined to expenditure attributable to those investments, and the Tribunal upheld CIT(A)'s deletion of the AO's broader Rule 8D disallowance. Recomputation of the written down value of the civil-work block for windmills was permitted where past assessments had restricted depreciation, and consequential additional depreciation was directed to be allowed under the depreciation provisions. Provision for mine closure computed in accordance with Ministry guidelines on a scientific basis was held deductible as business expenditure under general deductibility principles, and the CIT(A)'s allowance of that provision was sustained; revenue appeal dismissed.
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