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TMI Blog2016 (9) TMI 1187X X X X Extracts X X X X X X X X Extracts X X X X ..... te for the Opponent JUDGMENT ( Per : Honourable Mr. Justice KS Jhaveri ) 1. This Tax Appeal under Section 260A of the Income-tax Act, 1961 is filed against the order dated 24.03.2006 passed by the Income Tax Appellate Tribunal, Ahmedabad Bench 'B' (Special Bench) in ITA No.831/Ahd/1998 raising the following substantial question of law: "Whether in the facts and circumstances of the case, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was set off against the share premium in the books of accounts but was claimed in the computation of income as a deduction. The Assessing Officer disallowed the claim of the assessee vide order dated 25.03.1997. 3. Against the said order, the assessee filed appeal before the CIT(A), which came to be partly allowed, vide order dated 23.02.1998. Being aggrieved by the order of CIT(A), the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... expenses. According to the assessee, the expenses incurred were in respect of issuance of convertible debentures. The facts indicate that a portion of the convertible debentures was converted into equity shares and thereby, the assessee company got enduring benefits. Since capital can be raised by converting debentures into equity shares, we are of the view that expenditure incurred by the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X
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