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    <title>1971 (8) TMI 83 - PUNJAB AND HARYANA High Court</title>
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    <description>Commission paid to borrow shares for furnishing security to obtain stay of tax recovery was treated as non-deductible business expenditure, following the assessee&#039;s earlier reference and despite reliance on a later Supreme Court ruling. Legal expenses connected with income-tax matters were allowed as deductible business expenditure on the authority cited by the Court. The Appellate Assistant Commissioner could enhance the assessment by correcting carried-forward loss and depreciation because appellate power under section 31 extended to matters already on record and did not require a new source of income; this was not barred by rectification provisions. Payment to release an irrevocable letter of credit for acquiring plant was held to be capital expenditure, as it formed part of a capital acquisition transaction.</description>
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      <description>Commission paid to borrow shares for furnishing security to obtain stay of tax recovery was treated as non-deductible business expenditure, following the assessee&#039;s earlier reference and despite reliance on a later Supreme Court ruling. Legal expenses connected with income-tax matters were allowed as deductible business expenditure on the authority cited by the Court. The Appellate Assistant Commissioner could enhance the assessment by correcting carried-forward loss and depreciation because appellate power under section 31 extended to matters already on record and did not require a new source of income; this was not barred by rectification provisions. Payment to release an irrevocable letter of credit for acquiring plant was held to be capital expenditure, as it formed part of a capital acquisition transaction.</description>
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