Per Abdul Razack, Judicial Member - The assessee, a public limited company, filed the return declaring a loss of Rs. 59,63,119 worked out in the following manner :

     As is evident from the details of the computation statement, the assessee claimed a sum of Rs. 1,89,84,676 as deferred revenue expenditure. The Assessing Officer has stated that when the details were called for by him, it was represented to him that they were all public issue expenses and formed part of the total deferred revenue expenditure of Rs. 2,20,11,231 shown in the balance-sheet under Miscellaneous Expenditure. The Assessing Officer informed the assessee-company that the said expendi- ture of Rs. 1,89,84,676 was not allowable as public