IPO Expenditure Allowed Under Section 37 Despite Form 3CD and ITR Discrepancy - Tax Audit Report Cannot Trigger Disallowance

ITAT reversed CPC's disallowance of IPO expenditure under s.37 where variation existed between Form 3CD and ITR values. Following Kalpesh Synthetics precedent, ITAT held that disallowance cannot be made solely based on tax audit report observations. The tribunal directed deletion of IPO cost disallowance under s.37(1). On DDT credit under s.115-O, matter remanded to AO for verification and appropriate credit determination after providing opportunity of hearing to assessee. AO directed to follow due process and decide based on facts and applicable law. .....

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