Discount on issue of ESOP is allowable expenditure u/s 37: ITAT

Sec. 14A – curative in nature, but the expenditure cannot be assumed as non apportionable

ITAT Mumbai held In the case of HDFC Bank Limited vs. DCIT that in case of composite business yielding two streams of income, taxable and tax-exempt, apportionment of the expenses of the business would be required to be made in terms of sec. 14A r/w r. 8D, which rule is mandatory. Not so doing would be to defeat and, rather,

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