The Tribunal while dismissing the appeal of the revenue held that, the lease rentals received is allowable for set off against the lease rentals paid. The land on which the lease rental received from and paid was the same. Accordingly the excess expenditure on the same is also allowed to be capitalized as the project of construction of hotel had not commenced business operations. (AY. 2013-14)
ACIT v. Central Park Infrastructure Development P. Ltd. (2019) 76 ITR 76 (SN) (Delhi)(Trib.)
S. 37(1) : Business expenditure-Not commenced business operations-lease rentals is allowed to be set off against lease rentals paid as well as excess expenditure allowable for capitalization.