( 1 ) HINDUSTHAN Gas and Industries Ltd. , the assessee, incurred expenditure of Rs. 10,080 and Rs. 50,687, respectively, for payment of professional charges to its solicitors, Messrs. Orr, Dignam and Co. , for preparing a prospectus in connection with the issue of its preference shares and payment of underwriting commission and brokerage for the issue of the same, in the assessment year 1964-65, the corresponding previous year having ended on the 31st March, 1964. In its assessment to income-tax the assessee claimed deduction of the said expenditure from its business income. The ITO disallowed the claim on the ground that the said items were not expenditure of a revenue nature. On appeal, the AAC confirmed the order of the ITO. There was a further appeal by the assessee to the Tribunal. It was contended on behalf of the assessee before the Tribunal, inter alia, that the said amounts of expenditure should be treated as revenue expenditure. It was further contended that the said expenditure was incurred in respect of issue of not equity shares but redeemable preference shares. It was submitted that there was hardly any difference between a debenture and redeemab