Court Rules Preparatory Expenses Before Business Start Are Deductible, Not Capitalized; Clarifies Readiness vs. Operation Distinction.

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....Non setup of business - disallowance of deduction for expenditure incurred - Tribunal failed to appreciate the difference between the assessee being ready to commence business and the date from which it conducts business or, as in this, allowed to conduct. It has to be understood that business does not conform to, metaphorically speaking, the “cold start” doctrine. There is, in most cases, hiatus between the time a person or entity is ready to do business and when business is conducted. During this period, expenses are incurred towards keeping the business primed up. These expenses cannot be capitalized as suggested by the authorities below. - HC....