CIT v. Shree Synthetics Ltd.

162 ITR 819High Court1986#2995 most cited

What is CIT v. Shree Synthetics Ltd. authority for?

Expenses incurred in connection with a public issue of shares or debentures are allowable as revenue expenditure eligible for deduction under section 35D of the Income-tax Act. This includes expenses related to Qualified Institutional Buyers (QIBs).

39

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2015 to 2025.

Also referred to as

CIT v. Shree Synthetics Ltd. · section 35D · preliminary expenses · public issue of shares · debentures · QIB expenditure · revenue expenditure · deduction

Sections most often in play

Section 35DSection 271(1)(c)Section 14ASection 80A(5)Section 143(3)Section 37Section 80-IA(4)Section 1512

Issues it is cited on

section 2(d)section 57(i)section 35dpreliminary expensessection 46section 46asection 80a(5)interest on refundtransferor companysection 36(1)(viia)section 35section 40(a)(i)

Judgments citing CIT v. Shree Synthetics Ltd.

DCIT, Circle-1(1)(1), Ahmedabad vs. Adani Enterprises Ltd., Ahmedabad

In the result appeal of the Revenue is hereby partly allowed

ITA 336/AHD/2020[2014-15]Status: DisposedITAT Ahmedabad17 Aug 2022AY 2014-15

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

For Respondent: Shri Vartik Choksi, A.R
Section 1Section 143(3)

…ing as under: 30. We have heard the rival contentions of both the parties and perused the materials available on record. In this regard, we find pertinent to refer the judgment of Hon’ble Madhya Pradesh High Court in the case of CIT vs. Shree Synthetics Ltd. 162 ITR 819 cited above. The relevant extract of the judgment is reproduced as under: The word 'being' has been used in section 35D(2)(c )(iv) by way of illustration and is not restricted only to the words 'underwriting commission, brokerage and charges for drafting, typing, printing and advertisement of the prospectus'. There are the following stages in con…

DCIT, Circle-1(1)(1), Ahmedabad vs. Adani Enterprises Ltd., Ahmedabad

In the result appeal of the Revenue is hereby partly allowed

ITA 285/AHD/2020[2013-14]Status: DisposedITAT Ahmedabad17 Aug 2022AY 2013-14

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

For Respondent: Shri Vartik Choksi, A.R
Section 1Section 143(3)

…ing as under: 30. We have heard the rival contentions of both the parties and perused the materials available on record. In this regard, we find pertinent to refer the judgment of Hon’ble Madhya Pradesh High Court in the case of CIT vs. Shree Synthetics Ltd. 162 ITR 819 cited above. The relevant extract of the judgment is reproduced as under: The word 'being' has been used in section 35D(2)(c )(iv) by way of illustration and is not restricted only to the words 'underwriting commission, brokerage and charges for drafting, typing, printing and advertisement of the prospectus'. There are the following stages in con…

Adani Enterprises Ltd., Ahmedabad vs. The Dy. Commissioner of Income Tax, Circle-1(1)(1), Ahmedabad

Appeal of the Revenue is hereby dismissed

ITA 2035/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad15 Jul 2022AY 2011-12

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedasstt. Sr.No.

For Appellant: Shri S.N. Soparkar, Sr. Advocate with Shri Vartik Choksi, A.RFor Respondent: Shri Mohd. Usman, C.I.T.DR
Section 143(3)Section 28Section 35Section 92C

…allowable only to the extent of exhaustive list of expenses mentioned under the provision of section 35D of the Act. As per the assessee, the issue has been answered by the Hon’ble Madhya Pradesh High Court in case of CIT vs. Shree Synthetics Ltd reported in 162 ITR 819 where it was held that deduction under the provision of section 35D was not restricted to the extent of the list of expenses provided therein. As such, the list of expenses are illustrious in nature and therefore the same cannot be restricted. Therefore, following the judgment of Hon’ble Madhya Pradesh High Court its claim should be allowed. 24.…

Yes Bank Limited, Mumbai vs. DCIT 2 (2)(2), Mumbai

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

ITA 3500/MUM/2018[2013-14]Status: DisposedITAT Mumbai28 Jun 2022AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT
Section 14ASection 35DSection 40

…buyers are only a class of investors, the issue of shares to QIB have been considered as public issue. The expenses in connection with public issue of shares or debentures of the company are allowable. Reliance is placed on CIT v. Shree Synthetics Ltd. [1986] 162 ITR 819 (MP). Hence on the merits of the issue, the QIB expenditure can be treated as revenue expenditure and eligible for deduction under section 35D of the Income-tax Act is confirmed. Hence on merits of the issue as well as the fact that the same issue has been allowed in the earlier years and the Department cannot come upon in appeals in the subseque…

Yes Bank Ltd., Mumbai vs. DCIT 2(2)(2), Mumbai

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

ITA 3499/MUM/2018[2012-13]Status: DisposedITAT Mumbai28 Jun 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT
Section 14ASection 35DSection 40

…buyers are only a class of investors, the issue of shares to QIB have been considered as public issue. The expenses in connection with public issue of shares or debentures of the company are allowable. Reliance is placed on CIT v. Shree Synthetics Ltd. [1986] 162 ITR 819 (MP). Hence on the merits of the issue, the QIB expenditure can be treated as revenue expenditure and eligible for deduction under section 35D of the Income-tax Act is confirmed. Hence on merits of the issue as well as the fact that the same issue has been allowed in the earlier years and the Department cannot come upon in appeals in the subseque…

Yes Bank Limited, Mumbai vs. DCIT - 2(2)(2), Mumbai

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

ITA 3498/MUM/2018[2011-12]Status: DisposedITAT Mumbai28 Jun 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT
Section 14ASection 35DSection 40

…buyers are only a class of investors, the issue of shares to QIB have been considered as public issue. The expenses in connection with public issue of shares or debentures of the company are allowable. Reliance is placed on CIT v. Shree Synthetics Ltd. [1986] 162 ITR 819 (MP). Hence on the merits of the issue, the QIB expenditure can be treated as revenue expenditure and eligible for deduction under section 35D of the Income-tax Act is confirmed. Hence on merits of the issue as well as the fact that the same issue has been allowed in the earlier years and the Department cannot come upon in appeals in the subseque…

DCIT- 2(2)(2), Mumbai vs. Yes Bank Ltd., Mumbai

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

ITA 3238/MUM/2018[2013-14]Status: DisposedITAT Mumbai28 Jun 2022AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT
Section 14ASection 35DSection 40

…buyers are only a class of investors, the issue of shares to QIB have been considered as public issue. The expenses in connection with public issue of shares or debentures of the company are allowable. Reliance is placed on CIT v. Shree Synthetics Ltd. [1986] 162 ITR 819 (MP). Hence on the merits of the issue, the QIB expenditure can be treated as revenue expenditure and eligible for deduction under section 35D of the Income-tax Act is confirmed. Hence on merits of the issue as well as the fact that the same issue has been allowed in the earlier years and the Department cannot come upon in appeals in the subseque…

DCIT- 2(2)(2), Mumbai vs. Yes Bank Ltd., Mumbai

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

ITA 3237/MUM/2018[2012-13]Status: DisposedITAT Mumbai28 Jun 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT
Section 14ASection 35DSection 40

…buyers are only a class of investors, the issue of shares to QIB have been considered as public issue. The expenses in connection with public issue of shares or debentures of the company are allowable. Reliance is placed on CIT v. Shree Synthetics Ltd. [1986] 162 ITR 819 (MP). Hence on the merits of the issue, the QIB expenditure can be treated as revenue expenditure and eligible for deduction under section 35D of the Income-tax Act is confirmed. Hence on merits of the issue as well as the fact that the same issue has been allowed in the earlier years and the Department cannot come upon in appeals in the subseque…

DCIT 2(2)(2), Mumbai vs. Yes Bank Ltd., Mumbai

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

ITA 3236/MUM/2018[2011-12]Status: DisposedITAT Mumbai28 Jun 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT
Section 14ASection 35DSection 40

…buyers are only a class of investors, the issue of shares to QIB have been considered as public issue. The expenses in connection with public issue of shares or debentures of the company are allowable. Reliance is placed on CIT v. Shree Synthetics Ltd. [1986] 162 ITR 819 (MP). Hence on the merits of the issue, the QIB expenditure can be treated as revenue expenditure and eligible for deduction under section 35D of the Income-tax Act is confirmed. Hence on merits of the issue as well as the fact that the same issue has been allowed in the earlier years and the Department cannot come upon in appeals in the subseque…

M/S Subex Ltd vs. The Commissioner of Income Tax-III

In the result, appeal is partly allowed as indicated

ITA/378/2015HC Karnataka01 Oct 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 143Section 154Section 200Section 260Section 263Section 35D

…than seven years.” 15. A conjoint reading of these provisions would indicate that the phrase “being” employed in explaining the cost of project plays a significant role in answering this question. In the case of CIT V/s. Shree Synthetics Ltd., [(1986) 162 ITR 819 (MP)], the Hon’ble Madhya Pradesh High Court has held thus: “It was not disputed before us that there are the following stages in connection with the issue of shares for public subscription : (1) issue of prospectus and - 27 - invitation to the public to subscribe, (2) making of calls, that is, entertainment of applic…

Yes Bank Ltd., Mumbai vs. DCIT -2(2)(2), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 3497/MUM/2018[2010-11]Status: DisposedITAT Mumbai14 Jul 2020AY 2010-11

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2010-11

For Appellant: Mr. Yogesh A. Thar/Ms. Vidhi Doshi, ARFor Respondent: Mr. Purushottam Tripuri, DR
Section 143(3)Section 35DSection 40

…buyers are only a class of investors, the issue of shares to QIB have been considered as public issue. The expenses in connection with public issue of shares or debentures of the company are allowable. Reliance is placed on CIT v. Shree Synthetics Ltd. [1986] 162 ITR 819 (MP). Hence on the merits of the issue, the QIB expenditure can be treated as revenue expenditure and eligible for deduction under section 35D of the Income-tax Act is confirmed. Hence on merits of the issue as well as the fact that the same issue has been allowed in the earlier years and the Department cannot come upon in appeals in the subseque…

Ashok Leyland Ltd., Chennai vs. DCIT, Chennai

In the result, the appeal of the Revenue in ITA

ITA 2834/CHNY/2014[1995-96]Status: DisposedITAT Chennai23 Sept 2016AY 1995-96

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

For Appellant: Shri. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. Arun C. Bharath, IRS, CIT
Section 35D(2)Section 35D(2)(c)

…y those expenditure which are specifically mentioned: therein and nothing beyond. In the light of the decision of this Court referred to above, we reject .the reliance placed on the decision of the Madhya Pradesh High Court by the assessee, reported in [1986] 162 ITR 819 (Commissioner of Income Tax vs. Shree Synthetics Ltd). 4.2.1 From the chronology of.events, it was noticed that the appellant has filed this appeal on 29.1.2010 much before the decision of the Madras High Court (supra) in appellant's own case which has pronounced its order on 20.6.2012., After the pronouncement of this order, most of the argumen…

DCIT, Chennai vs. Ashok Leyland Ltd., Chennai

In the result, the appeal of the Revenue in ITA

ITA 2827/CHNY/2014[2007-08]Status: DisposedITAT Chennai23 Sept 2016AY 2007-08

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

For Appellant: Shri. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. Arun C. Bharath, IRS, CIT
Section 35D(2)Section 35D(2)(c)

…y those expenditure which are specifically mentioned: therein and nothing beyond. In the light of the decision of this Court referred to above, we reject .the reliance placed on the decision of the Madhya Pradesh High Court by the assessee, reported in [1986] 162 ITR 819 (Commissioner of Income Tax vs. Shree Synthetics Ltd). 4.2.1 From the chronology of.events, it was noticed that the appellant has filed this appeal on 29.1.2010 much before the decision of the Madras High Court (supra) in appellant's own case which has pronounced its order on 20.6.2012., After the pronouncement of this order, most of the argumen…

DCIT, Chennai vs. Ashok Leyland Ltd., Chennai

In the result, the appeal of the Revenue in ITA

ITA 2825/CHNY/2014[2005-06]Status: DisposedITAT Chennai23 Sept 2016AY 2005-06

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

For Appellant: Shri. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. Arun C. Bharath, IRS, CIT
Section 35D(2)Section 35D(2)(c)

…y those expenditure which are specifically mentioned: therein and nothing beyond. In the light of the decision of this Court referred to above, we reject .the reliance placed on the decision of the Madhya Pradesh High Court by the assessee, reported in [1986] 162 ITR 819 (Commissioner of Income Tax vs. Shree Synthetics Ltd). 4.2.1 From the chronology of.events, it was noticed that the appellant has filed this appeal on 29.1.2010 much before the decision of the Madras High Court (supra) in appellant's own case which has pronounced its order on 20.6.2012., After the pronouncement of this order, most of the argumen…

ACIT, Chennai vs. Thiru Arooran Sugars Limited, Chennai

In the result, the appeals of the assessee are partly

ITA 1559/CHNY/2015[2011-12]Status: DisposedITAT Chennai18 Dec 2015AY 2011-12

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A.Nos.1346, 1347, 1348 /Mds/2015 "नधा"रण वष" /Assessment Year : 1999-00, 2000-01, 2005-06

For Appellant: Shri. R. Vijayaraghavan, AdvocateFor Respondent: Shri. A.B. Koli, IRS, JCIT
Section 143(3)Section 147Section 35D

…आयकर अपील"य अ"धकरण, ’ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी चं" पूजार",लेखा सद"य एवं "ीजी. पवन कुमार,"या"यकसद"यकेसम" BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI G. PAVAN KUMAR, JUDICIAL MEMBER आयकर अपील सं./I.T.A.Nos.1346, 1347, 1348 /Mds/2015 "नधा"रण वष" /Assessment year : 1999-00, 2000-01, 2005-06 M/s. Thiru Arooran Sugars Ltd, Vs. The Assistant Commissioner of Eldorado, V floor, Income Tax, 112,Mahatma Gandhi Road, Corporate Circle 3(2) Nungambakkam, Chennai. Chennai 600 034. आयकर अपील सं./I.T.A.No.1559/Mds/2015 "नधा"रण वष" /Assessment year : 1999-2000. The A…

Thiru Arooran Sugars Ltd., Chennai vs. ACIT, Chennai

In the result, the appeals of the assessee are partly

ITA 1348/CHNY/2015[2005-06]Status: DisposedITAT Chennai18 Dec 2015AY 2005-06

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A.Nos.1346, 1347, 1348 /Mds/2015 "नधा"रण वष" /Assessment Year : 1999-00, 2000-01, 2005-06

For Appellant: Shri. R. Vijayaraghavan, AdvocateFor Respondent: Shri. A.B. Koli, IRS, JCIT
Section 143(3)Section 147Section 35D

…आयकर अपील"य अ"धकरण, ’ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी चं" पूजार",लेखा सद"य एवं "ीजी. पवन कुमार,"या"यकसद"यकेसम" BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI G. PAVAN KUMAR, JUDICIAL MEMBER आयकर अपील सं./I.T.A.Nos.1346, 1347, 1348 /Mds/2015 "नधा"रण वष" /Assessment year : 1999-00, 2000-01, 2005-06 M/s. Thiru Arooran Sugars Ltd, Vs. The Assistant Commissioner of Eldorado, V floor, Income Tax, 112,Mahatma Gandhi Road, Corporate Circle 3(2) Nungambakkam, Chennai. Chennai 600 034. आयकर अपील सं./I.T.A.No.1559/Mds/2015 "नधा"रण वष" /Assessment year : 1999-2000. The A…

Thiru Arooran Sugars Ltd., Chennai vs. ACIT, Chennai

In the result, the appeals of the assessee are partly

ITA 1347/CHNY/2015[2000-01]Status: DisposedITAT Chennai18 Dec 2015AY 2000-01

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A.Nos.1346, 1347, 1348 /Mds/2015 "नधा"रण वष" /Assessment Year : 1999-00, 2000-01, 2005-06

For Appellant: Shri. R. Vijayaraghavan, AdvocateFor Respondent: Shri. A.B. Koli, IRS, JCIT
Section 143(3)Section 147Section 35D

…आयकर अपील"य अ"धकरण, ’ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी चं" पूजार",लेखा सद"य एवं "ीजी. पवन कुमार,"या"यकसद"यकेसम" BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI G. PAVAN KUMAR, JUDICIAL MEMBER आयकर अपील सं./I.T.A.Nos.1346, 1347, 1348 /Mds/2015 "नधा"रण वष" /Assessment year : 1999-00, 2000-01, 2005-06 M/s. Thiru Arooran Sugars Ltd, Vs. The Assistant Commissioner of Eldorado, V floor, Income Tax, 112,Mahatma Gandhi Road, Corporate Circle 3(2) Nungambakkam, Chennai. Chennai 600 034. आयकर अपील सं./I.T.A.No.1559/Mds/2015 "नधा"रण वष" /Assessment year : 1999-2000. The A…

Thiru Arooran Sugars Ltd., Chennai vs. ACIT, Chennai

In the result, the appeals of the assessee are partly

ITA 1346/CHNY/2015[1999-00]Status: DisposedITAT Chennai18 Dec 2015AY 1999-00

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A.Nos.1346, 1347, 1348 /Mds/2015 "नधा"रण वष" /Assessment Year : 1999-00, 2000-01, 2005-06

For Appellant: Shri. R. Vijayaraghavan, AdvocateFor Respondent: Shri. A.B. Koli, IRS, JCIT
Section 143(3)Section 147Section 35D

…आयकर अपील"य अ"धकरण, ’ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी चं" पूजार",लेखा सद"य एवं "ीजी. पवन कुमार,"या"यकसद"यकेसम" BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI G. PAVAN KUMAR, JUDICIAL MEMBER आयकर अपील सं./I.T.A.Nos.1346, 1347, 1348 /Mds/2015 "नधा"रण वष" /Assessment year : 1999-00, 2000-01, 2005-06 M/s. Thiru Arooran Sugars Ltd, Vs. The Assistant Commissioner of Eldorado, V floor, Income Tax, 112,Mahatma Gandhi Road, Corporate Circle 3(2) Nungambakkam, Chennai. Chennai 600 034. आयकर अपील सं./I.T.A.No.1559/Mds/2015 "नधा"रण वष" /Assessment year : 1999-2000. The A…

M/S Subex Ltd., Bangalore vs. CIT, Bangalore

In the result appeal of the Assessee is partly allowed

ITA 689/BANG/2014[2008-09]Status: DisposedITAT Bangalore19 Jun 2015AY 2008-09

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz Assessment Year : 2008-09

For Appellant: Shri Arvind Sonde, AdvocateFor Respondent: Shri S. Radhakrishna, CIT-III(DR)
Section 115JSection 263Section 35D

…niture, fittings and railway sidings (including expenditure on development of land and buildings). 1.11 The assessee wishes to place reliance on the decision of Madhya Pradesh High court in the case of Commissioner of Income tax v. Shree Synthetics Ltd [1986] 162 ITR 819 (Copy of the decision enclosed as Annexure 2) which was rendered in the context of section 35D (2) of the Act wherein it has been held that: “The word ‘being’ has been used in section 35D(2)(c)iv by way of illustration and is not restricted only to the words ‘underwriting commission, brokerage and charges for drafting, typing, printing and advert…