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2016 (2) TMI 424 - AT - Income TaxAddition being processing and consortium fee paid to PNB - CIT(A) has deleted the disallowance - Held that:- There is no basis for the revenue to contend that any expenditure incurred towards loan is not an eligible business expenditure. Such an expenditure is revenue expenditure as has also been held by the Apex Court in the case of India Cements Ltd. vs. CIT (1965 (12) TMI 22 - SUPREME Court ) - Decided against revenue Addition on account of stamp duty charges paid for issue of debenture certificates - CIT(A) has deleted the disallowance - Held that:- The debentures are loans raised by the assessee, therefore, any expenditure including stamp duty for such debentures is eligible for deduction for computing income of the appellant. A Coordinate Bench of Tribunal in the case of DCIT vs. UAG Builders (P) Ltd.(2012 (9) TMI 764 - ITAT DELHI ) while considering the issue of fully convertible debentures has deleted the addition concluding there was no contingency involved in the accrual of liability with reference to the interest on the debentures. Also rightly observed that debentures, whether fully or partly or optionally convertible, are nothing but debt till the date of conversion and any interest paid on these debentures is allowable as normal business expenditure - Decided against revenue
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