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    <title>2023 (11) TMI 336 - ITAT AHMEDABAD</title>
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    <description>Project expenses on lignite and power projects were treated as revenue expenditure because the projects were a continuation and expansion of the existing business under common control, management and funds, so pre-commencement costs were allowable. Interest paid for delayed sales tax was held compensatory and deductible. Prior period expenses were sent back for verification of crystallisation. Rule 8D was held inapplicable for the year, and no section 14A disallowance survived where own funds were sufficient. Event-related contributions lacked business nexus and were disallowed, while payment to an exempt scientific research association did not attract section 40(a)(ia) because no tax was deductible. Depreciation, accrual issues on doubtful receipts, and consequential book profit additions were also decided largely in favour of the assessee.</description>
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      <description>Project expenses on lignite and power projects were treated as revenue expenditure because the projects were a continuation and expansion of the existing business under common control, management and funds, so pre-commencement costs were allowable. Interest paid for delayed sales tax was held compensatory and deductible. Prior period expenses were sent back for verification of crystallisation. Rule 8D was held inapplicable for the year, and no section 14A disallowance survived where own funds were sufficient. Event-related contributions lacked business nexus and were disallowed, while payment to an exempt scientific research association did not attract section 40(a)(ia) because no tax was deductible. Depreciation, accrual issues on doubtful receipts, and consequential book profit additions were also decided largely in favour of the assessee.</description>
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