TMI Blog2000 (2) TMI 26X X X X Extracts X X X X X X X X Extracts X X X X ..... g that the stamp duty paid on debenture issue was an allowable item of deduction under section 35D of the Income-tax Act, 1961. Section 35D deals with amortisation of certain preliminary expenses. Under section 35D(1) where an assessee, being an Indian company, incurs, after March 31, 1970, expenditure specified in sub-section (2) of section 35D before the commencement of his business, or after th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt of stamp duty on the debenture issue is not an item of allowable deduction. The Tribunal has rejected the contention. We agree with the decision of the Tribunal. The expression in connection with the issue of public subscription of the debentures of the company essentially for the expansion of the business is a very wide expression and it would certainly include the stamp duty payable by the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mitted. On the facts, the Tribunal came to the conclusion that after protracted negotiations in respect of the demands on the fresh charter of demands, conciliation proceedings were held and under the said proceedings it was decided that a lump sum amount would be paid at a particular rate to the workers for the period January 1, 1985, up to December 31, 1986. The Tribunal, therefore, accepted the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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