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Interest expense on perpetual bonds allowable as deduction
Case Law Details
- Case Name
- ICICI Bank Limited Vs ACIT (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2010-11
- Courts
- All ITAT, ITAT Mumbai
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ICICI Bank Limited Vs ACIT (ITAT Mumbai)
ITAT Mumbai held that mere RBI recognition of debt instrument as additional tier/ capital doesn’t change the nature of perpetual debt instrument. Hence, interest expenses on perpetual bonds, allowable as deduction under Section 36(1)(iii) of the Income Tax Act, 1961
Facts-
During the course of assessment, the A.O also noticed that assessee has claimed interest expenditure u/s 36(1)(iii)of the Act in respect of perpetual bonds issued by the assessee bank. On query, the assessee explained that these bonds have been issued to various ins...






