Amortization & allowability of Expenses under section 35D & 37- ITAT remands matter back to AO

DCIT Vs L & T Access Distribution Services Ltd. (ITAT Mumbai) On the one hand, it is argued by the Ld. A.R. for the assessee before the Ld. CIT(A) that the expenditure of Rs.13.30 crores is for the purpose of setting up of the business of the assessee, but at the same time argued that the expenditure qualifies for amortization under section 35D of the Act, to which the Ld. CIT(A) has agreed and allowed the amount of Rs.13.30 crores to be amortized under section 35D of the Act. How the expenditures are to be amortized when assessee has come up with a specific plea before the AO that the ded...