https://www.taxtmi.com/caselaws?id=782795 ITAT Ahmedabad-AT dismissed the cross-appeals of assessee and Revenue, upholding the CIT(A)'s restriction of disallowance u/s 14A to 1% of the book value of mutual fund investments, holding the AO's higher disallowance excessive. The Tribunal allowed depreciation on "Infrastructure Usage Facility" as an intangible asset, following its own earlier decision in assessee's case and applying the principle that depreciation allowed in earlier years cannot be denied merely for alleged non-use in a subsequent year. It further held that income from operating and maintaining railway siding infrastructure under a sub-concession arrangement qualified for deduction u/s 80IA(4)(i), applying the proviso and recognizing assessee as a duly acknowledged transferee/contractor. en-us Wed, 24 Sep 2025 00:00:00 +0530 Thu, 04 Dec 2025 09:19:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782795 ITAT Ahmedabad-AT dismissed the cross-appeals of assessee and Revenue, upholding the CIT(A)'s restriction of disallowance u/s 14A to 1% of the book value of mutual fund investments, holding the AO's higher disallowance excessive. The Tribunal allowed depreciation on "Infrastructure Usage Facility" as an intangible asset, following its own earlier decision in assessee's case and applying the principle that depreciation allowed in earlier years cannot be denied merely for alleged non-use in a subsequent year. It further held that income from operating and maintaining railway siding infrastructure under a sub-concession arrangement qualified for deduction u/s 80IA(4)(i), applying the proviso and recognizing assessee as a duly acknowledged transferee/contractor. Case-Laws Income Tax Wed, 24 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782795