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Assessee has raised the ground that on the facts and circumstances of thecaseand in law, the ld. CIT(A) erred in disallowing the deduction u/s. 35D of the Act on the assumption that the shares may have been allotted only to selected Qualified Institutional Buyers ("QIBs").

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Section 35D of the Income Tax Act, 1961- Business Expenditure- Qualified Institutional Buyers (QIBs) are a class of investors as a part of the large investor community and the companies sought for QIB issues because the funds can be raised within a short span and this is an extremely important investment for larger investors and since the buyers are only a class of investors, the issue of shares to QIB have been considered as public issue, thus, expenses in connection with public issue of shares or debentures of the company are allowable as revenue expenditure and eligible for deduction under section 35D . - YES BANK LTD. V/s DY. CIT - [2020] 206 TTJ 913 (ITAT-MUMBAI)