https://www.taxtmi.com/caselaws?id=289395 Commission paid for underwriting a fresh issue of preference shares was treated as expenditure incurred to raise capital, not as revenue expenditure. The court held that expenditure directed to procuring capital retains its capital character whether incurred at the company's flotation or later, and its accounting treatment cannot change that nature. Because the statutory deduction was limited to expenditure not of a capital nature, the underwriting commission was not allowable under Section 9(2)(ix). The argument that "profits" meant only the profits of the particular year was not finally decided, as it was unnecessary to the result. en-us Mon, 28 Feb 1921 00:00:00 +0530 Wed, 29 Jul 2020 11:27:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289395 Commission paid for underwriting a fresh issue of preference shares was treated as expenditure incurred to raise capital, not as revenue expenditure. The court held that expenditure directed to procuring capital retains its capital character whether incurred at the company's flotation or later, and its accounting treatment cannot change that nature. Because the statutory deduction was limited to expenditure not of a capital nature, the underwriting commission was not allowable under Section 9(2)(ix). The argument that "profits" meant only the profits of the particular year was not finally decided, as it was unnecessary to the result. Case-Laws Indian Laws Mon, 28 Feb 1921 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289395