Upfront lease premium on lease-hold land allowable as deduction u/s. 37(1) of Income Tax Act

ACIT Vs Britannia Industries (ITAT Kolkata) ITAT Kolkata held that upfront lease premium on lease-hold land is nothing but advance payment of rent and the same is not a capital expenditure and as such the deduction should be allowed u/s 37(1) of the Income Tax Act. Facts- The assessee is a public limited company and is engaged in the business of manufacturing and trading bakery and dairy products. AO noticed that the assessee has entered into certain international and specific domestic transactions. Accordingly, the case was referred to TPO. AO made upward adjustment towards corporate guarante...