https://www.taxtmi.com/caselaws?id=445197 Delhi HC upheld the Tribunal's decision allowing depreciation deduction on towers constructed during the assessment year and upfront loan processing fee as revenue expenditure. The court held that towers used for business purposes, even passively through lease arrangements, qualify for depreciation under Section 32(1). The "used for business" requirement was construed liberally to include passive use where profits had clear nexus with the towers. Regarding loan processing charges, the court ruled that upfront payment amortized over five years for accounting purposes doesn't preclude lump sum deduction in the payment year, as the loan was raised solely for business purposes. en-us Tue, 31 Oct 2023 00:00:00 +0530 Thu, 02 Nov 2023 09:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445197 Delhi HC upheld the Tribunal's decision allowing depreciation deduction on towers constructed during the assessment year and upfront loan processing fee as revenue expenditure. The court held that towers used for business purposes, even passively through lease arrangements, qualify for depreciation under Section 32(1). The "used for business" requirement was construed liberally to include passive use where profits had clear nexus with the towers. Regarding loan processing charges, the court ruled that upfront payment amortized over five years for accounting purposes doesn't preclude lump sum deduction in the payment year, as the loan was raised solely for business purposes. Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445197