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TMI Blog2008 (12) TMI 781X X X X Extracts X X X X X X X X Extracts X X X X ..... Heard the learned counsel for the appellant and the learned counsel for the respondent. The appellant has raised following questions of law- (i) Whether the facts and circumstances of the case and in law the ITAT was justified in upholding the order of CIT (A) in deleting the disallowance of ₹ 20,15,85,238/- made by way of capital expenditure on the initial issue expenditure on the mu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Tribunal dated 3rd May, 2007. The Tribunal gave its finding as under- 2.4 The intial expenses directly incurred for raising capital are in nature and cannot be allowed by way of deduction as revenue expenditure. But the proposition would apply in a case where the expenditure incurred and the capital raised is by one and the same assessee. In the assessee s case, the expenses have been incurred ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the expenses incurred were not in dispute. The expenses incurred were the assessee s own expenditure and it was a part and parcel of the profit-making activity of the assessee. The expenditure had a direct nexus with the assessee s own business of asset management. There was no valid basis to treat the expenses in question as capital in character, as incurring of such expenditure did not result i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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