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The Tribunal in [2022] 27 ITR (Trib)-OL 1 (ITAT[Ahm] held that where the expenditure had been incurred for study of capital market by SBI Cap in connection with initial public offer it could not be allowed as deduction treating it as revenue under the provisions of section 37(1) of the Act.
Such expenditure compare to expenditure on feasibility study which does not end in procurement of any asset or advantage of enduring nature albeit as a mere opinion. Such expenses are relatable to businessespecially for those in existing running business.
The bench took reference from a High Court decision which in particular concerned expenditure in refund of amounts oversubscribed during public subscription which is found to have proximity to section 35D bucket of expenses.

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