ITAT Rules: EPC Consortium Not AOP, Section 80IA Deduction Valid, Capital Gains at 20%, Business Write-offs Allowed.

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....The ITAT ruled on multiple issues in favor of the assessee. Key determinations include: consortium arrangement for EPC contracts where members are independently responsible cannot be treated as AOP, thus no TDS was required on interest payments to JV. The assessee qualified for Section 80IA deduction as a developer of infrastructure facilities. For depreciable long-term capital assets, though deemed as short-term gains u/s 50, the applicable tax rate remains 20% u/s 112. Write-offs of advances given during business operations were allowed as business losses. Compensation paid to promoters for invoked pledged shares was deemed revenue expenditure, allowable u/s 37(1). AIR reconciliation differences of 0.03% were dismissed given accepted books of accounts. Interest on delayed TDS payments was ruled non-deductible as business expenditure.....