https://www.taxtmi.com/caselaws?id=793117 Section 35D amortisation for pre-operative expenses was allowed because the deduction had already been accepted in the initial years and could not be denied later without disturbing the original allowance. ESOP-related expenditure reimbursed to the holding company was held deductible under section 37(1) as a real business outgo incurred for employees and wholly for business purposes. Share issue expenses remained capital in nature because they were incurred to expand the capital base, so they were not allowable as revenue expenditure even if the funds were used for working capital. The penalty ground under section 270A was not entertained as premature. The appeal succeeded only in part. en-us Fri, 05 Jun 2026 00:00:00 +0530 Tue, 09 Jun 2026 07:50:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793117 Section 35D amortisation for pre-operative expenses was allowed because the deduction had already been accepted in the initial years and could not be denied later without disturbing the original allowance. ESOP-related expenditure reimbursed to the holding company was held deductible under section 37(1) as a real business outgo incurred for employees and wholly for business purposes. Share issue expenses remained capital in nature because they were incurred to expand the capital base, so they were not allowable as revenue expenditure even if the funds were used for working capital. The penalty ground under section 270A was not entertained as premature. The appeal succeeded only in part. Case-Laws Income Tax Fri, 05 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793117