Land Development Expenses and Institutional Aid Allowed as Business Deductions Under Section 143(3) for Government Entity

ITAT upheld CIT(A)'s decision favoring the assessee on multiple disputed deductions. The City Environment Expenses were allowed as sunk costs incurred for development of notified area, not generating future revenue. Contribution & Aid Expenses to other institutions were permitted as business expenditure following precedent that such expenditure indirectly benefits business operations. IMC Transfer Expenses were allowed considering assessee's status as state government wing, established audit procedures, and consistency with prior years' treatment. Land acquisition and diversion expenses were validated as revenue-neutral since they formed part of Work-in-Progress/stock, effectively resulting in no deduction claim. ITAT emphasized the principle of consistency in tax authorities' approach absent changes in facts or law, maintaining prior assessment treatments under Section 143(3). .....

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