Business set-up is distinct from commercial commencement: once a...

Business set-up is distinct from commercial commencement: once a division is established and ready to perform its functions, expenditure cannot be denied solely because commercial operations have not begun. Contemporaneous evidence recording completion of the first phase and commencement of production supports the division's operational status; subsequent financial distress or action against assets cannot retrospectively alter that status. Appellate authorities must consider written submissions and material evidence, including annual reports, and provide reasoned findings rather than merely adopting assessment reasoning. Expenditure of a newly established division cannot be categorised wholesale as capital; deductibility of each item remains subject to applicable statutory conditions.