CIT v. Hongkong and Shanghai Banking Corporation Ltd. (Bom) (HC) (UR) Editorial: SLP of revenue is dismissed (SLP No.18521 of 2019 dt.02/08/2019)(2019) 416 ITR 124 (St.)(SC)

S.37(1) : Business expenditure : Bank NRI deposits mobilisation expenditure – replacement of shares – Held to be allowable.[ S.44AC ]

Assessee assist and facilitate the investments by NRIs.  The amount was spent towards administrative and other related expenses and the entire expenditure was for the purposes of head office and, therefore, no restrictions in terms of S.44C should be imposed. Replacement of shares by assessee to its clients is  held to be allowable expenditure . (ITA No. 1561 of 2016, dt.06/02/2019)