https://www.taxtmi.com/caselaws?id=778226 ITAT MUMBAI (AT) largely ruled for the assessee on multiple heads: Explanation 2 to s.43B does not apply to clauses (b)-(d); contributions to local organisations, rural development, advertisement-film costs, software expenditure, ESOPs as remuneration, HO expense allocations, administrative retirement-fund expenses, depreciation on block assets, and transfer-related expenditures were allowed as revenue deductions. Sales-tax and TUF interest subsidies were held to be capital receipts (not taxable). Slump-sale treatment/s.50B did not apply to the Scheme of Arrangement; capital receipt treatment upheld and s.50B addition deleted. Dividend from foreign company was decided against the assessee. Disallowances under s.43B for amounts paid/written back were allowed; set-off of interest paid/received with the department was accepted. Deduction u/s 80-IA allowed for rail and specified units. en-us Tue, 09 Sep 2025 00:00:00 +0530 Fri, 12 Sep 2025 08:45:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778226 ITAT MUMBAI (AT) largely ruled for the assessee on multiple heads: Explanation 2 to s.43B does not apply to clauses (b)-(d); contributions to local organisations, rural development, advertisement-film costs, software expenditure, ESOPs as remuneration, HO expense allocations, administrative retirement-fund expenses, depreciation on block assets, and transfer-related expenditures were allowed as revenue deductions. Sales-tax and TUF interest subsidies were held to be capital receipts (not taxable). Slump-sale treatment/s.50B did not apply to the Scheme of Arrangement; capital receipt treatment upheld and s.50B addition deleted. Dividend from foreign company was decided against the assessee. Disallowances under s.43B for amounts paid/written back were allowed; set-off of interest paid/received with the department was accepted. Deduction u/s 80-IA allowed for rail and specified units. Case-Laws Income Tax Tue, 09 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778226