https://www.taxtmi.com/caselaws?id=772460 The ITAT Delhi allowed the assessee's appeal regarding IPO expenditure under Section 35D, holding that 92% of share issue expenditure utilized for working capital constituted revenue expenditure, while 8% used for capital expenditure was allowable under Section 35D. The tribunal ruled that excise duty exemption under Notification No. 50/2003 for Uttarakhand constituted capital receipt, not revenue receipt, as the exemption aimed at capital asset acquisition for industrialization. The amendment to Section 2(24)(xviii) was held inapplicable since it specifically excluded "exemption" from its scope. Consequently, the excise duty exemption was excluded from book profit computation under Section 115JB for MAT purposes. en-us Fri, 06 Jun 2025 00:00:00 +0530 Mon, 09 Jun 2025 07:29:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772460 The ITAT Delhi allowed the assessee's appeal regarding IPO expenditure under Section 35D, holding that 92% of share issue expenditure utilized for working capital constituted revenue expenditure, while 8% used for capital expenditure was allowable under Section 35D. The tribunal ruled that excise duty exemption under Notification No. 50/2003 for Uttarakhand constituted capital receipt, not revenue receipt, as the exemption aimed at capital asset acquisition for industrialization. The amendment to Section 2(24)(xviii) was held inapplicable since it specifically excluded "exemption" from its scope. Consequently, the excise duty exemption was excluded from book profit computation under Section 115JB for MAT purposes. Case-Laws Income Tax Fri, 06 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772460