IDFC Projects Ltd. v. ACIT (2020) 84 ITR 30 (SN) (Mum.)(Trib.)

S. 37(1) : Business expenditure-Abandoned project-Link with existing business-Allowable as deduction-Payment of bonus commensurate with efforts-Allowable as deduction. [S. 36(2)]

Tribunal held that since no consideration was received by the assessee on account of winding up of the special purpose vehicle, the entire investment was written off. The write off was nothing but write off of an expenditure on an abandoned project. The project in question had inextricable link with the assessee’s existing business and hence, the expenditure was allowable as revenue expenditure.The Tribunal held that the team was successful in negotiating the deal with a buyer for purchase of the special purpose vehicle. The payment of bonus was commensurate with the efforts rendered by the team over a period of time in order to exit the project. The ad hoc disallowance  made by the Assessing Officer was to be deleted.(AY.2012-13)