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ITAT held that the right to collect toll is an intangible asset, so depreciation at 25% and consequential additional depreciation were allowable. It also upheld reduction of actual cost by the NHAI subsidy under Explanation 10 to section 43(1), disallowing excess depreciation, and sustained rejection of the resurfacing expense provision as contingent and not scientifically estimated. Capitalisation of negative grant liability was disallowed, with depreciation on that amount also rejected. The assessee's alternative claim for enhanced deduction under section 80IA on additions arising from the same eligible infrastructure activity was allowed. Interest under sections 234A, 234B, 234C and 234D was to be recomputed as directed. Penalty under section 271(1)(c) was deleted because disallowance of a claim does not by itself prove inaccurate particulars.
ITAT held that the right to collect toll is an intangible asset, so depreciation at 25% and consequential additional depreciation were allowable. It also upheld reduction of actual cost by the NHAI subsidy under Explanation 10 to section 43(1), disallowing excess depreciation, and sustained rejection of the resurfacing expense provision as contingent and not scientifically estimated. Capitalisation of negative grant liability was disallowed, with depreciation on that amount also rejected. The assessee's alternative claim for enhanced deduction under section 80IA on additions arising from the same eligible infrastructure activity was allowed. Interest under sections 234A, 234B, 234C and 234D was to be recomputed as directed. Penalty under section 271(1)(c) was deleted because disallowance of a claim does not by itself prove inaccurate particulars.
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