PCIT v Reliance Natural Resources Ltd. (2019) 267 Taxman 644 (Bom.)(HC)/Editorial : SLP of Revenue dismissed , PCIT v. Reliance Natural Resources Ltd. (2022) 286 Taxman 435 (SC)

S. 37(1) : Business expenditure–Raising loan-Capital or revenue-Expenses for issuing Foreign Convertible Bond only on interpretation of DTAA-Question of law. [S. 260A]

Revenue urged the following question of law for consideration ;

“Whether on the facts and in the circumstances of the case and in law, the Tribunal was justified in deleting the disallowance of expenses of Rs.28 58, 28, 246 / on the issue of Foreign Currency Convertible Bond without appreciating the fact that expenses were incurred for the issue of FCCB of Rs.1304.13 Crores which is capital in nature “ ?

Question of law is admitted. (ITANO. 623 of 2017 dt 26-08-2019) (AY. 2007-08)