Compulsorily convertible debenture issue costs and s68 funding receipts: treated as borrowing, revenue expenses allowed, additions deleted.

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....Expenses incurred predominantly for issuance of compulsorily convertible debentures were held to be revenue in nature since such instruments constitute borrowing and the amortisation regime under s.35D was inapplicable; the disallowance of alleged share issue expenses was therefore rightly deleted. Addition under s.68 for funds received against such debentures was unsustainable as the assessee proved identity, genuineness through banking channels, and creditworthiness through financial records, and the "source of source" requirement inserted w.e.f. AY 2023-24 was held inapplicable; the deletion was upheld. Professional consultancy charges for project viability were allowable u/s 37(1) as incurred wholly and exclusively for business expediency, warranting deletion of the disallowance; appeal allowed. - ITAT....