Redemption premium on business-funding FCCBs is revenue expenditure and may be spread across the prescribed maturity period.

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Full Text of the Document

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....Redemption premium on foreign currency convertible bonds issued to raise and use business funds is characterised as revenue expenditure, because the liability arises on issuance and does not acquire a capital asset or enduring advantage. The notes state that expenditure connected with issuing debentures or obtaining loans is likewise revenue in nature. The premium liability arises in the year of issue and may be proportionately spread over the bonds' prescribed maturity period; it is immaterial whether redemption is at will or only at maturity. The text further records that no substantial question of law arose on either the revenue character or timing of the deduction.....