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    <title>2026 (10) TMI 515 - ITAT CHENNAI</title>
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    <description>Revenue deductibility of Bio-Pharma Division expenditure depends on whether the business had been set up and was ready to perform its intended functions, rather than solely on the later commencement of commercial operations. Annual-report evidence of completion of the first project phase and commencement of production supports that status; later financial-enforcement events and uncertain segment-turnover allocation do not negate it for the relevant year. Blanket capitalisation of all divisional expenditure is inappropriate, since depreciation, interest on borrowed capital and scientific-research expenditure must independently satisfy their statutory conditions. On these facts, the full capital disallowance was unsustainable and deleted.</description>
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