Deductibility of borrowing-related expenses recognised as revenue expenditure under income tax law; prior contrary Board instruction withdrawn.

Expenditure incurred in connection with borrowing money - including stamp duty, registration fees and lawyer's fees - is allowable as revenue expenditure when borrowing is incidental to the carrying on of business under section 37(1). The Board has withdrawn the earlier circular that conflicted with the Supreme Court's decision, by issuing Instruction No.187/CBDT dated 6-7-1970, thereby aligning departmental guidance with the Court's ruling.

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