https://www.taxtmi.com/caselaws?id=346794 Expenditure on issuing foreign currency convertible bonds was treated as revenue expenditure because the bonds were regarded as debt instruments akin to borrowings and had not been converted into equity, so the amount was deductible. Disallowance under section 40(a)(i) was deleted for reimbursement and for foreign payments covered by treaty protection where the sums were not taxable in India or no withholding obligation arose under section 195, though the disallowance already sustained remained undisturbed. The section 14A read with Rule 8D disallowance could not be mechanically imported into clause (f) of Explanation 1 to section 115JB, so the book-profit adjustment was rejected and the appellate estimate was upheld. The Indonesian consultant issue was remanded, while the global depository receipt listing expenditure disallowance was sustained. en-us Fri, 11 Aug 2017 00:00:00 +0530 Tue, 23 Jun 2026 15:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=346794 Expenditure on issuing foreign currency convertible bonds was treated as revenue expenditure because the bonds were regarded as debt instruments akin to borrowings and had not been converted into equity, so the amount was deductible. Disallowance under section 40(a)(i) was deleted for reimbursement and for foreign payments covered by treaty protection where the sums were not taxable in India or no withholding obligation arose under section 195, though the disallowance already sustained remained undisturbed. The section 14A read with Rule 8D disallowance could not be mechanically imported into clause (f) of Explanation 1 to section 115JB, so the book-profit adjustment was rejected and the appellate estimate was upheld. The Indonesian consultant issue was remanded, while the global depository receipt listing expenditure disallowance was sustained. Case-Laws Income Tax Fri, 11 Aug 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=346794