Foreign Currency Bond (FCCB) expenses allowable as revenue expenses

ACIT Vs ORG Informatics Limited (ITAT Ahmedabad) Assessee stated that the issue of FCCB is a Foreign Currency Bond issue and it is basically a debt instrument in the nature of loan and all issue expenses related to that are allowable as revenue expenses. This issue is not a public issue but is made to class of persons. Hence provisions of Section 35D are not applicable. The assessee submitted before the Assessing Officer that since this is a debit instrument on the date on which it is issued, expenses incurred on this should be allowed as revenue expenses. As per the terms of issue the holder ...