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The ITAT ruled in favor of the assessee, allowing deduction of premium paid on redemption of Optionally Fully Convertible Debentures (OFCDs). The Tribunal rejected the AO's contention that funds from OFCDs were not used for business purposes, finding that the assessee had used these funds to pay security deposit for land possession and development, which constituted legitimate business expenditure. Following precedent in CIT v. Raymond Ltd and Madras Industrial Investment Corpn. Ltd., the ITAT held that premium paid upon redemption of debentures qualifies as revenue expenditure. The Tribunal upheld the CIT(A)'s deletion of disallowances for both assessment years under consideration.
The ITAT ruled in favor of the assessee, allowing deduction of premium paid on redemption of Optionally Fully Convertible Debentures (OFCDs). The Tribunal rejected the AO's contention that funds from OFCDs were not used for business purposes, finding that the assessee had used these funds to pay security deposit for land possession and development, which constituted legitimate business expenditure. Following precedent in CIT v. Raymond Ltd and Madras Industrial Investment Corpn. Ltd., the ITAT held that premium paid upon redemption of debentures qualifies as revenue expenditure. The Tribunal upheld the CIT(A)'s deletion of disallowances for both assessment years under consideration.
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