The assessee increased its authorised share capital solely for issuing bonus shares by capitalising its free reserves and claimed deduction of the fees paid to the Registrar of Companies. The Tribunal held that the issue of bonus shares merely represented reallocation of existing funds without any inflow of fresh capital or expansion of the capital base. Accordingly, the expenditure was revenue in nature and allowable in full and could not be restricted under section 35D. (AY. 2020-21).
Asst. CIT v. Neuzen Finance (P.) Ltd. (2025) 124 ITR 43 / 175 taxmann.com 582 (Mum.)(Trib.)
S. 37(1): Business expenditure-Registrar of Companies fees for increase in authorised share capital-Increase for issue of bonus shares by capitalisation of reserves-Revenue expenditure allowable in full. [S. 35D]
Leave a Reply