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    <title>2025 (12) TMI 978 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad-AT allowed the assessee&#039;s appeals substantially. It upheld eligibility for deduction u/s 80IB(9) by treating each oil well as a separate undertaking, following earlier years and the jurisdictional HC ruling rejecting retrospective application of the Explanation. Depreciation on goodwill u/s 32 and higher depreciation at 60% on oil wells and oil field assets were directed to be allowed, as was additional depreciation u/s 32(1)(iia), maintaining consistency with prior years and SC confirmation. Weighted deduction u/s 35(1)(ii) for payment to a non-approved research trust was rightly disallowed. ALP adjustment on HO expense allocation under the Production Sharing Contract was deleted. AO was directed to verify and grant MAT credit and full TDS credit, and to re-examine and allow deduction u/s 42 in accordance with DRP directions.</description>
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    <pubDate>Fri, 12 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 978 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=783438</link>
      <description>ITAT Ahmedabad-AT allowed the assessee&#039;s appeals substantially. It upheld eligibility for deduction u/s 80IB(9) by treating each oil well as a separate undertaking, following earlier years and the jurisdictional HC ruling rejecting retrospective application of the Explanation. Depreciation on goodwill u/s 32 and higher depreciation at 60% on oil wells and oil field assets were directed to be allowed, as was additional depreciation u/s 32(1)(iia), maintaining consistency with prior years and SC confirmation. Weighted deduction u/s 35(1)(ii) for payment to a non-approved research trust was rightly disallowed. ALP adjustment on HO expense allocation under the Production Sharing Contract was deleted. AO was directed to verify and grant MAT credit and full TDS credit, and to re-examine and allow deduction u/s 42 in accordance with DRP directions.</description>
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      <pubDate>Fri, 12 Dec 2025 00:00:00 +0530</pubDate>
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