TDR inventory-cost deduction timing dispute: prior-period reassessment disallowance deleted; s.270A Keyman penalty and s.36(1)(iii) interest disallowance removed

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....TDR expenditure treated as inventory cost was held allowable in the year to which the AO had himself earlier attributed it; having disallowed it as "prior period" in a later year on the footing that it pertained to the earlier year, the revenue could not take a contradictory stand to deny deduction in both years. The reassessment disallowance was therefore directed to be deleted. Penalty under s. 270A on disallowance of Keyman insurance premium was deleted because the issue was debatable and the AO failed to record the requisite finding specifying whether the case involved under-reporting or misreporting. Disallowance of interest under s. 36(1)(iii) on interest-free advances was deleted since interest-free funds exceeded the advances, attracting the presumption that advances were from such funds - ITAT....