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The ITAT upheld the allowance of contributions to the Core Settlement Guarantee Fund as deductible business expenditure. The assessee, a clearing corporation wholly owned by a stock exchange, established the Core SGF pursuant to SEBI directions to ensure unconditional availability of funds for settlement obligations. Revenue disallowed the contributions and the CIT(A) sustained the disallowance, but a co-ordinate Bench had earlier ruled in favour of the parent entity on the same issue for other assessment years. Applying that precedent, the ITAT held the contributions were incurred wholly and exclusively for the purpose of business and allowed the deduction, deciding the appeals in favour of the assessee.
The ITAT upheld the allowance of contributions to the Core Settlement Guarantee Fund as deductible business expenditure. The assessee, a clearing corporation wholly owned by a stock exchange, established the Core SGF pursuant to SEBI directions to ensure unconditional availability of funds for settlement obligations. Revenue disallowed the contributions and the CIT(A) sustained the disallowance, but a co-ordinate Bench had earlier ruled in favour of the parent entity on the same issue for other assessment years. Applying that precedent, the ITAT held the contributions were incurred wholly and exclusively for the purpose of business and allowed the deduction, deciding the appeals in favour of the assessee.
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