The assessee, a non-banking financial company engaged in investment activities and trading in securities, claimed deduction of Portfolio Management Services (PMS) fees paid to SEBI-regulated portfolio managers. The Tribunal held that the assessee was authorised by the Reserve Bank of India to carry on the business of acquisition and investment in shares and securities and the expenditure incurred on PMS was wholly and exclusively for carrying on such business. The fees constituted business expenditure allowable under section 37(1). The Revenue’s contention that the expenditure was not deductible under section 48 was rejected and the order of the Commissioner (Appeals) allowing the deduction was upheld. The assessee was also entitled to support the order of the Commissioner (Appeals) by invoking Rule 27 of the Income-tax (Appellate Tribunal) Rules, 1963. The Tribunal held that the Revenue had satisfactorily explained the delay of 101 days in filing the appeal as it occurred on account of the time taken in obtaining administrative approvals through the departmental hierarchy. The delay being bona fide, it was condoned in the interest of justice.  (AY. 2022-23).