https://www.taxtmi.com/caselaws?id=24844 Expenditure incurred in connection with issuing new shares is characterised as capital expenditure because its object was to strengthen the company's capital structure; consequently such costs are not deductible as business revenue expenditure. The court distinguished fees paid merely to obtain permission to increase authorised capital (which may be noncapital if not resulting in actual capital increase) from brokerage and commission paid on an actual share issue, which are capital in nature and not allowable. The matter was remanded for verification under appellate remand procedure on one issue, and a certification was refused on the principal question favouring the Revenue. en-us Fri, 15 Apr 1988 00:00:00 +0530 Thu, 05 Feb 2026 23:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24844 Expenditure incurred in connection with issuing new shares is characterised as capital expenditure because its object was to strengthen the company's capital structure; consequently such costs are not deductible as business revenue expenditure. The court distinguished fees paid merely to obtain permission to increase authorised capital (which may be noncapital if not resulting in actual capital increase) from brokerage and commission paid on an actual share issue, which are capital in nature and not allowable. The matter was remanded for verification under appellate remand procedure on one issue, and a certification was refused on the principal question favouring the Revenue. Case-Laws Income Tax Fri, 15 Apr 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24844