Assessee wins on moulds expenditure, capital subsidy treatment, and Section 14A disallowance verification

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....ITAT allowed the assessee's appeal on multiple grounds. The Tribunal held that expenditure on moulds and dies constituted revenue expenditure as these items require frequent replacement, noting the department's acceptance of this treatment in subsequent years. Regarding capital investment subsidy from J&K Government, ITAT ruled that Explanation 10 to Section 43(1) was inapplicable as the subsidy aimed at industrial development rather than asset cost subsidization, and Finance Act 2015 amendments were prospective only. Excise duty refund was treated as capital receipt following Supreme Court precedent. On Section 14A disallowance, the matter was remanded to AO for verification of actual exempt income earned during the year. The Tribunal conf.........