https://www.taxtmi.com/caselaws?id=794853 Section 35D(2)(c) confines amortisation of expenses for public subscription, underwriting, brokerage, prospectus and related listing costs to an assessee that is a company. A SEBI-registered REIT constituted as a trust remains a business trust, not a company, under the Income-tax Act; its pass-through fiscal treatment confirms its distinct status. The company-specific language cannot be interpreted liberally or harmoniously to treat trust units as company shares or debentures. Substance over form does not override this express statutory limitation. Consequently, a REIT cannot claim deduction under section 35D(2)(c) for public subscription, IPO and unit-listing expenditure. en-us Wed, 08 Jul 2026 00:00:00 +0530 Mon, 13 Jul 2026 09:18:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794853 Section 35D(2)(c) confines amortisation of expenses for public subscription, underwriting, brokerage, prospectus and related listing costs to an assessee that is a company. A SEBI-registered REIT constituted as a trust remains a business trust, not a company, under the Income-tax Act; its pass-through fiscal treatment confirms its distinct status. The company-specific language cannot be interpreted liberally or harmoniously to treat trust units as company shares or debentures. Substance over form does not override this express statutory limitation. Consequently, a REIT cannot claim deduction under section 35D(2)(c) for public subscription, IPO and unit-listing expenditure. Case-Laws Income Tax Wed, 08 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794853