Interest on Late TDS Payment Allowed as Business Expense Under Section 37(1); 100% Depreciation and Section 80IA Deductions Upheld
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....The ITAT allowed the deduction of interest on late payment of TDS as a business expenditure under section 37(1), rejecting the Revenue's classification of TDS as income tax under section 40(a)(ii). Sales promotion expenses disallowed by the AO were restored, as the assessee adequately substantiated that the expenses were wholly and exclusively for business purposes. The claim for 100% depreciation on iron hoardings was upheld, recognizing their enduring benefit and aligning with precedent favoring the assessee. Prior period expenses were allowed. The assessee's claim for deduction under section 80IA was affirmed, with the Tribunal confirming the assessee's status as an infrastructure developer engaged in constructing foot over bridges and bus shelters, thereby entitling it to the deduction, contrary to the Revenue's assertion that it was merely an advertising firm.....