Assessee obtained a new loan and paid fees to the bank as ‘front end fees’. Assessee amortized this expense under section 35D of the Act. AO disallowed assessee’s claim. The High Court  held that front end fees is part of interest under S.2(28A) of the Act and front end fees constitutes interest liability which is spread over a period of time. Obtaining such loan and paying interest to service it ensured long term benefit to the assessee and such expenditure incurred is revenue in nature entitled to be amortized and cannot be capital in nature. HC remanded back the matter to the tribunal for recomputing assessment.  (ITA No. 496 of 2008 dt. 18-04-2019) (AY. 2004-05)