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But as per the original message, the expenditure has been spread over 2 years. It has not been kept as an advance in the first year. Therefore if the expenditure is charged off the in the books over a period of two years, then it can be claimed in year 1 on incurrance basis or if it is capital in nature then it can be claimed as part of block under depreciation route. I do not think it is possible not to claim in the expenditure charged off in the books in Year 1 and thereafter claim the full expenditure in Year 2.

There is no specific provision in the Income tax Act which permits transfer of MAT credit from the Transferor Company to the Transferee Company in the event of Amalgamation, in my opinion. Can some expert clarify if my view is incorrect?