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    <title>2022 (3) TMI 1135 - ITAT MUMBAI</title>
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    <description>Prior-period expenses are allowable when the liability crystallises during the relevant year, even if the expenditure relates to earlier periods. Amortisation of stamp duty and related costs for increase in authorised share capital was treated as eligible preliminary expenditure under section 35D. No disallowance under section 14A was warranted where interest-free funds exceeded exempt-income investments and no separate non-interest expenditure nexus was shown. Bank bad-debt deductions under sections 36(1)(vii) and 36(1)(viia) operate independently within the statutory scheme. A penalty paid for breach of RBI directions was held inadmissible under section 37(1). Reassessment under section 147 was upheld on tangible material, while the ESOP-related quantum issue and consequential penalty were remitted for fresh adjudication.</description>
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    <pubDate>Wed, 23 Mar 2022 00:00:00 +0530</pubDate>
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      <description>Prior-period expenses are allowable when the liability crystallises during the relevant year, even if the expenditure relates to earlier periods. Amortisation of stamp duty and related costs for increase in authorised share capital was treated as eligible preliminary expenditure under section 35D. No disallowance under section 14A was warranted where interest-free funds exceeded exempt-income investments and no separate non-interest expenditure nexus was shown. Bank bad-debt deductions under sections 36(1)(vii) and 36(1)(viia) operate independently within the statutory scheme. A penalty paid for breach of RBI directions was held inadmissible under section 37(1). Reassessment under section 147 was upheld on tangible material, while the ESOP-related quantum issue and consequential penalty were remitted for fresh adjudication.</description>
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