Upfront payment of processing fee on the loan - revenue...

Upfront payment of processing fee on the loan - revenue expenditure u/s 37 or capital expenditure - merely because the loan processing charges though paid upfront but amortized over a period of five years, solely to be in consonance with the mercantile system of accounting, deduction of the entire charges in lump sum in the year in which the same were paid could not be denied to the respondent/assessee. - HC