Calico Dyeing & Printing Works v. CIT

34 ITR 265High Court1958#1818 most cited

What is Calico Dyeing & Printing Works v. CIT authority for?

For claiming a deduction of interest paid on borrowed capital under Section 36(1)(iii), an assessee must show that the capital was used for business purposes; the nature of the asset acquired (revenue or capital) with such capital is irrelevant.

63

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2008 to 2025.

Also referred to as

Calico Dyeing & Printing Works v. CIT · 34 ITR 265 · Section 36(1)(iii) · interest on borrowed capital deduction · business purpose · revenue asset · capital asset · loan utilization · income tax deduction

Sections most often in play

Section 14ASection 36(1)(iii)Section 41(1)Section 68Section 10(2)(iii)Section 142(1)Section 143(2)Section 143(3)

Issues it is cited on

section 36(l)(iii)section 36(l)project completion methodsection 10(2)percentage completion methodsection 36(1)(iii)section 245dsection 43(1)put to usemercantile system of accountingsection 36(1)section 36

Judgments citing Calico Dyeing & Printing Works v. CIT

PR. CIT -3 vs. DLF LTD.(FOMERLY KNOWN AS DLF UNIVERSAL LTD.

ITA/926/2016HC Delhi06 Mar 2025

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR

…the capital borrowed by the assessee was an item of deduction. That, the utilization of the capital was irrelevant for the purposes of adjudicating the claim for deduction under section 36(1)(iii) of the Act -Calico Dyeing & Printing Works v. CIT [1958] 34 ITR 265 (Bom.). In that judgment, it has been laid down that where an assessee claims deduction of interest paid on capital borrowed, all that the assessee had to show was that the capital which was borrowed was used for business purpose in the relevant year of account and it did not matter whether the capital was borrowed in order to acquire a reve…

PR. CIT -3 vs. DLF LTD. (FORMERLY KNOWN AS DLF UNIVERSAL LTD.)

ITA/928/2016HC Delhi06 Mar 2025

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR

…the capital borrowed by the assessee was an item of deduction. That, the utilization of the capital was irrelevant for the purposes of adjudicating the claim for deduction under section 36(1)(iii) of the Act -Calico Dyeing & Printing Works v. CIT [1958] 34 ITR 265 (Bom.). In that judgment, it has been laid down that where an assessee claims deduction of interest paid on capital borrowed, all that the assessee had to show was that the capital which was borrowed was used for business purpose in the relevant year of account and it did not matter whether the capital was borrowed in order to acquire a reve…

DCIT- 2(3)(1), MUMBAI vs. PARANJAPE SCHEMES CONSTRUCTION LIMITED , VILE PARLE EAST , MUMBAI

In the result, appeal of the assessee is partly allowed for statistical purposes and the Revenue appeal is dismissed

ITA 5501/MUM/2024[2021-22]Status: DisposedITAT Mumbai29 Jan 2025AY 2021-22

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 143(3)Section 14ASection 41(1)Section 68

…e utilization of the capital was irrelevant for the purposes of adjudicating the claim for deduction under Section 36(1)(iii) of the Act (See judgment of the Bombay High Court in the case of Calico Dyeing and Printing Works v. CIT, Bombay City-II, reported in 34 ITR 265). In that judgment, it has been laid down that where an assessee claims deduction of interest paid on capital borrowed, all that the assessee had to show was that the capital which was borrowed was used for business purpose in the relevant year of account and it did not matter whether the capital was borrowed in order to acquire a revenue asset or…

PARANJAPE SCHEMES CONSTRUCTION LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - 2(3)(1), MUMBAI

In the result, appeal of the assessee is partly allowed for statistical purposes and the Revenue appeal is dismissed

ITA 5274/MUM/2024[AY 2021-22]Status: DisposedITAT Mumbai29 Jan 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 143(3)Section 14ASection 41(1)Section 68

…e utilization of the capital was irrelevant for the purposes of adjudicating the claim for deduction under Section 36(1)(iii) of the Act (See judgment of the Bombay High Court in the case of Calico Dyeing and Printing Works v. CIT, Bombay City-II, reported in 34 ITR 265). In that judgment, it has been laid down that where an assessee claims deduction of interest paid on capital borrowed, all that the assessee had to show was that the capital which was borrowed was used for business purpose in the relevant year of account and it did not matter whether the capital was borrowed in order to acquire a revenue asset or…

DCIT, NEW DELHI vs. M/S. MAHATTA TOWERS PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 1137/DEL/2017[2012-13]Status: DisposedITAT Delhi10 Oct 2024AY 2012-13

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singh[Assessment Year : 2012-13] Dcit, Vs M/S. Mahatta Towers Pvt.Ltd., Circle-16(1), 614, Plot No.54, Mahatta Towers, New Delhi. B Block, Community Center, Janakpuri, New Delhi-110058. Pan-Aaacm2109F Appellant Respondent Appellant By Shri Koushlender Tiwari, Cit Dr Respondent By Shri Ved Jain, Adv. Date Of Hearing 13.08.2024 Date Of Pronouncement 10.10.2024

Section 14Section 142(1)Section 143(2)Section 14A

…item of deduction. That, the utilization of the capital was irrelevant for the purposes of adjudicating the claim for deduction under s. 36(1)(iii) of the Act (see judgment of the Bombay High Court in the case of Calico Dyeing & Printing Works vs. CIT (1958) 34 ITR 265 (Bom)). In that judgment, it has been laid down that where an assessee claims deduction of interest paid on capital borrowed, all that the assessee had to show was that the capital which was borrowed was used for business purpose in the relevant year of account and it did not matter whether the capital was borrowed in order to acquire a revenue as…

ADD. CIT SPL RANGE--3, NEW DELHI vs. DLF LTD, NEW DELHI

ITA 5919/DEL/2019[2016-17]Status: DisposedITAT Delhi19 Jul 2023AY 2016-17

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmaita No.5978/Del/2017, A.Y. 2014-15 Ita No.2238/Del/2019, A.Y. 2015-16 Ita No.5919/Del/2019, A.Y. 2016-17

Section 143(3)Section 14ASection 801A

…ee on the capital borrowed by the assessee was an item of deduction. That, the utilization of the capital was irrelevant for the purposes of adjudicating the claim for deduction under section 36(1)(iii) of the Act -Calico Dyeing & Printing Works v. CIT [19581 34 ITR 265 (Bom.f In that judgment, it has been laid down that where an assessee claims deduction of interest paid on capital borrowed, all that the assessee had to show was that the capital which was borrowed was used for business purpose in the relevant year of account and it did not matter whether the capital was borrowed in order ITA 5978 & Ors. 9 to a…

ADD. CIT SPL RANGE--3, NEW DELHI vs. DLF LTD, NEW DELHI

ITA 2238/DEL/2019[2015-16]Status: DisposedITAT Delhi19 Jul 2023AY 2015-16

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmaita No.5978/Del/2017, A.Y. 2014-15 Ita No.2238/Del/2019, A.Y. 2015-16 Ita No.5919/Del/2019, A.Y. 2016-17

Section 143(3)Section 14ASection 801A

…ee on the capital borrowed by the assessee was an item of deduction. That, the utilization of the capital was irrelevant for the purposes of adjudicating the claim for deduction under section 36(1)(iii) of the Act -Calico Dyeing & Printing Works v. CIT [19581 34 ITR 265 (Bom.f In that judgment, it has been laid down that where an assessee claims deduction of interest paid on capital borrowed, all that the assessee had to show was that the capital which was borrowed was used for business purpose in the relevant year of account and it did not matter whether the capital was borrowed in order ITA 5978 & Ors. 9 to a…

ADDL. CIT, SPECIAL RANGE- 03, NEW DELHI vs. DLF LTD., NEW DELHI

ITA 5978/DEL/2017[2014-15]Status: DisposedITAT Delhi19 Jul 2023AY 2014-15

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmaita No.5978/Del/2017, A.Y. 2014-15 Ita No.2238/Del/2019, A.Y. 2015-16 Ita No.5919/Del/2019, A.Y. 2016-17

Section 143(3)Section 14ASection 801A

…ee on the capital borrowed by the assessee was an item of deduction. That, the utilization of the capital was irrelevant for the purposes of adjudicating the claim for deduction under section 36(1)(iii) of the Act -Calico Dyeing & Printing Works v. CIT [19581 34 ITR 265 (Bom.f In that judgment, it has been laid down that where an assessee claims deduction of interest paid on capital borrowed, all that the assessee had to show was that the capital which was borrowed was used for business purpose in the relevant year of account and it did not matter whether the capital was borrowed in order ITA 5978 & Ors. 9 to a…

MACROTECH DEVELOPERS LTD.(SUCCESSOR TO BELLISSIMO CROWN BUILDMART PVT LTD.,,MUMBAI vs. DCIT CENTRAL CIRCLE 7(3), MUMBAI

The appeal is allowed

ITA 2266/MUM/2022[2017-18]Status: DisposedITAT Mumbai17 Apr 2023AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Vijay Mehta, ARFor Respondent: Shri Manoj Kumar, CIT DR
Section 115JSection 14ASection 928Section 92B

…8-19 the capital borrowed by the assessee was an item of deduction. That, the utilization of the capital was irrelevant for the purposes of adjudicating the claim for deduction under section 36(1)(iii) of the Act - Calico Dyeing & Printing Works v. CIT [1958] 34 ITR 265 (Bom.). In that judgment, it has been laid down that where an assessee claims deduction of interest paid on capital borrowed, all that the assessee had to show was that the capital which was borrowed was used for business purpose in the relevant year of account and it did not matter whether the capital was borrowed in order to acquire a revenue as…

MACROTECH DEVELOPRS LTD,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 7(3), MUMBAI

The appeal is allowed

ITA 2239/MUM/2022[2018-19]Status: DisposedITAT Mumbai17 Apr 2023AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Vijay Mehta, ARFor Respondent: Shri Manoj Kumar, CIT DR
Section 115JSection 14ASection 928Section 92B

…8-19 the capital borrowed by the assessee was an item of deduction. That, the utilization of the capital was irrelevant for the purposes of adjudicating the claim for deduction under section 36(1)(iii) of the Act - Calico Dyeing & Printing Works v. CIT [1958] 34 ITR 265 (Bom.). In that judgment, it has been laid down that where an assessee claims deduction of interest paid on capital borrowed, all that the assessee had to show was that the capital which was borrowed was used for business purpose in the relevant year of account and it did not matter whether the capital was borrowed in order to acquire a revenue as…

ACIT, CIRCLE-3(1)(2), MUMBAI vs. FRONTLINE REALTY PVT. LTD, MUMBAI

In the result, the appeal filed by the Revenue in ITA No

ITA 7472/MUM/2018[2014-15]Status: DisposedITAT Mumbai24 Feb 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Vranda U Matkarni
Section 143(3)Section 263Section 36(1)(iii)

…d expenditure pertains to acquisition of revenue asset or capital asset. The (A.Ys.2014-15 & 2015-16) ACIT vs. M/s. Frontline Realty Pvt. Ltd. said decision of the Hon'ble High Court has relied on the decision of Calico Dyeing & Printing Works vs. CIT [1958] 34 ITR 265 (Bom), wherein it was held that the assessee has to prove that the borrowed capital was utilized for the purpose of its business. The relevant extract of the said decision is cited hereunder for ease of reference: FINDINGS : 4. From the facts found by the Tribunal on record, it is clear that assessee undertook two- fold activities. It bought and…

ACIT -893) (1) , MUMBAI vs. M/S. TRIPLE SECURITIES PVT. LTD, MUMBAI

ITA 2270/MUM/2021[2016-17]Status: DisposedITAT Mumbai20 Dec 2022AY 2016-17
For Appellant: Shri Nitesh JoshiFor Respondent: Ms. Samruddhi Hande
Section 143(3)Section 36Section 43C

…e on the capital borrowed by the assessee was an item of deduction. That, the utilization of the capital was irrelevant for the purposes of adjudicating the claim for deduction under section 36(1)(iii) of the Act - Calico Dyeing & Printing Works v. CIT [1958] 34 ITR 265 (Bom.). In that judgment, it has been laid down that where an assessee claims deduction of interest paid on capital borrowed, all that the assessee had to show was that the capital which was borrowed was used for business purpose in the relevant year of account and it did not matter whether the capital was borrowed in order to acquire a revenue as…

DY. COMMISSIONER OF INCOME TAX, CC-7(3), MUMBAI vs. M/S MACROTECH DEVELOPERS LTD (SUCCESSOR TO M/S LODHA IMPRESSION REAL ESTATE PVT LTD), MUMBAI

In the result, all the appeals of the revenue are dismissed

ITA 1894/MUM/2022[2015-2016]Status: DisposedITAT Mumbai21 Sept 2022AY 2015-2016
Section 143(3)

…ii) of the Act. The Hon’ble High Court also placed reliance on the decision of the Hon’ble Bombay High Court in the case of Calico Dyeing & Printing Works vs CIT reported M/s. MMR Social Housing Pvt. Ltd., (Earlier known as M/s. Lodha Buildcon Pvt. Ltd.,) in 34 ITR 265 (Bom) for the proposition that utilization of the capital was irrelevant for the purpose of adjudicating the claim of deduction u/s 36(1)(iii) of the Act. Ultimately the Hon’ble High Court concluded that interest expenditure could not be treated as capital expenditure nor could it be added to the work in progress. 4.4. In the instant case before…

ASSISTANT COMMISSIONER OF INCOME TAX,CC-7(3), MUMBAI vs. M/S MACROTECH DEVELOPERS LTD(SUCCESSOR TO M/S LODHA IMPRESSION REAL ESTATE PVT LTD)., MUMBAI

In the result, all the appeals of the revenue are dismissed

ITA 1892/MUM/2022[2013-14]Status: DisposedITAT Mumbai21 Sept 2022AY 2013-14
Section 143(3)

…ii) of the Act. The Hon’ble High Court also placed reliance on the decision of the Hon’ble Bombay High Court in the case of Calico Dyeing & Printing Works vs CIT reported M/s. MMR Social Housing Pvt. Ltd., (Earlier known as M/s. Lodha Buildcon Pvt. Ltd.,) in 34 ITR 265 (Bom) for the proposition that utilization of the capital was irrelevant for the purpose of adjudicating the claim of deduction u/s 36(1)(iii) of the Act. Ultimately the Hon’ble High Court concluded that interest expenditure could not be treated as capital expenditure nor could it be added to the work in progress. 4.4. In the instant case before…

ASSISTANT COMMISSIONER OF INCOME TAX,CC-7(3), MUMBAI vs. M/S MMR SOCIAL HOUSING PVT LTD (EARLIER KNOW AS M/S LODHA BUILDCON PVT LTD), MUMBAI

In the result, all the appeals of the revenue are dismissed

ITA 1891/MUM/2022[2013-2014]Status: DisposedITAT Mumbai21 Sept 2022AY 2013-2014
Section 143(3)

…ii) of the Act. The Hon’ble High Court also placed reliance on the decision of the Hon’ble Bombay High Court in the case of Calico Dyeing & Printing Works vs CIT reported M/s. MMR Social Housing Pvt. Ltd., (Earlier known as M/s. Lodha Buildcon Pvt. Ltd.,) in 34 ITR 265 (Bom) for the proposition that utilization of the capital was irrelevant for the purpose of adjudicating the claim of deduction u/s 36(1)(iii) of the Act. Ultimately the Hon’ble High Court concluded that interest expenditure could not be treated as capital expenditure nor could it be added to the work in progress. 4.4. In the instant case before…

COMMR.OF I.T.-I,HYD vs. A.P.GAS POWER COR.LTD,HYD

ITTA/135/2003HC Telangana14 Sept 2022

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

For Respondent: SRI CHALLA GUNARANJAN
Section 260Section 36Section 36(1)Section 37(1)

…e same as the transaction of invesrmenr. If rhis dichoromrr i" r--_. :_ becomes crcar that,rj"Hl,::j":rt:"T;:"; attracts rhe provisions of Secdon 36(l)(ur) of the Act. Thus, rhe dccision of the Bombay High Court in Calico Dyeing & printing Works v. CIT (1953) 34 ITR 265 (Bom)) and rhe ludgment of the Supreme Court India Cements Ltd. v. CIT (1966) 60 ITR 52 (SC)) have been given with reference to the borrowings made for th busrness, wh,e the a..iriolffi. il,.:. #:: Challapalli Sugars Ltd. v. CIT ((1975) 3SCC 572) was given with reference ro the borrowings which I I 7 7 could not be treated as made for the purpos…

ACIT 1 (1)(1), MUMBAI vs. M/S DOSTI REALTY LTD., MUMBAI

In the result, the appeal filed by the revenue is dismissed

ITA 7374/MUM/2019[2014-15]Status: DisposedITAT Mumbai06 Sept 2022AY 2014-15

Bench: Shr Pramod Kumar, Vp & Shri Amit Shukla, Jm आयकरअपीलसं./ I.T.A. No. 7374/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2014-15) Asst. Commissioner Of M/S Dosti Realty Ltd. (Formally Known As Friends Income Tax-1(1)(1), Development Corporation 579,Ayankar Bhavan, M.K बिधम/ (Imperia) Pvt. Ltd. Road, Mumbai-400020, 276,1St Floor, Lawrence & Vs. Mayo House, Mumbai - 400001, स्थायीलेखासं./जीआइआरसं./ Pan No Aabcf5801A (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri P.R. Rastogi, Ld. Dr प्रत्यथीकीओरसे/Respondent By : Shri Dr.K.Shivaram & Rahul Hakani, Ld. Ar सुनवाईकीतारीख/ : 14.06.2022 Date Of Hearing घोषणाकीतारीख / : 06.09.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Revenue Against Order Dated 19.09.2019, Passed By Ld. Cit (Appeals)-2, Mumbai For The Quantum Of Assessment Passed U/S 143(3) For Ay 2014-2015. The Revenue Has Raised The Following Grounds:-

For Appellant: Shri P.R. Rastogi, Ld. DRFor Respondent: Shri Dr.K.Shivaram & Rahul
Section 143(3)Section 36(1)(iii)

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHR PRAMOD KUMAR, VP & SHRI AMIT SHUKLA, JM आयकरअपीलसं./ I.T.A. No. 7374/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2014-15) Asst. Commissioner of M/s Dosti Realty Ltd. (formally known as Friends Income Tax-1(1)(1), Development Corporation 579,Ayankar Bhavan, M.K बिधम/ (Imperia) Pvt. Ltd. Road, Mumbai-400020, 276,1st Floor, Lawrence & Vs. Mayo House, Mumbai - 400001, स्थायीलेखासं./जीआइआरसं./ PAN No AABCF5801A (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant by : Shri P.R. Rastogi, Ld. DR प्रत्यथीकीओरसे/Respondent by : Shri Dr.K.Shi…

DCIT CC 7(3), MUMBAI vs. M/S PALAVA DWELLERS PVT. LTD., MUMBAI

In the result, appeal filed by the learned AO is dismissed and appeal of the assessee is allowed

ITA 1594/MUM/2019[2015-16]Status: DisposedITAT Mumbai31 Aug 2022AY 2015-16

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

For Appellant: Mr. Niraj Seth, ARFor Respondent: Mr. Praveen Shekhar, DR
Section 14ASection 36Section 36(1)(iii)Section 80G

…assessee was entitled to deduction under section 36(l)(iii) of the Act in respect of the interest on the loan obtained for execution of said project/' Relying on the another judgment of Hon'ble Bombay High Court in the case of Calico Dying and Printing Works 34 ITR 265 Bombay, Hon'ble Bombay High Court concluded that the interest expenditure relating to the borrowed capital is allowable u/s 36(l)(iii) of the Act. The relevant lines from the para 4 reads as under; "that, while adjudicating the claim for deduction under section 36(l)(iii) of the Act the nature of expense 0- whether the expenditure was on capital a…

LODHA DEVELOPERS LTD.(SUCCESSOR TO PALAVA DWELLERS PVT. LTD.),MUMBAI vs. DCIT, CC- 7(3), MUMBAI

In the result, appeal filed by the learned AO is dismissed and appeal of the assessee is allowed

ITA 1539/MUM/2019[2015-16]Status: DisposedITAT Mumbai30 Aug 2022AY 2015-16

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

For Appellant: Mr. Niraj Seth, ARFor Respondent: Mr. Praveen Shekhar, DR
Section 14ASection 36Section 36(1)(iii)Section 80G

…assessee was entitled to deduction under section 36(l)(iii) of the Act in respect of the interest on the loan obtained for execution of said project/' Relying on the another judgment of Hon'ble Bombay High Court in the case of Calico Dying and Printing Works 34 ITR 265 Bombay, Hon'ble Bombay High Court concluded that the interest expenditure relating to the borrowed capital is allowable u/s 36(l)(iii) of the Act. The relevant lines from the para 4 reads as under; "that, while adjudicating the claim for deduction under section 36(l)(iii) of the Act the nature of expense 0- whether the expenditure was on capital a…

TATA HOUSING DEVELOPMENT COMPANY LTD.,MUMBAI vs. DCIT- 8(3)(1), MUMBAI

In the result, the appeal filed by the assessee ITA

ITA 3491/MUM/2019[2015-16]Status: DisposedITAT Mumbai28 Jun 2022AY 2015-16

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singhm/S Tata Housing Vs. Dcit – 8(3)(1) Development Company Room No. 615, Ltd.,E Block, Voltas Aayakar Bhavan, Compound, Tb Kadam Mk Marg, Marg, Chinchpokli, Mumbai – 400020. Mumbai – 400033. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. :Aaact0191Q Appellant .. Respondent Dcit – 8(3)(1) Vs. M/S. Tata Housing Room No. 615, Aayakar Development Company Bhavan, Ltd.,E Block, Voltas Mk Marg, Compound, Tb Kadam Mumbai – 400020. Marg, Chinchpokli, Mumbai – 400033. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. :Aaact0191Q Appellant .. Respondent

For Appellant: Shri.Madhur Agarwal.ARFor Respondent: Shri.Ajay Kumar. CIT DR
Section 115JSection 143(2)Section 143(3)Section 14ASection 36(1)Section 36(1)(iii)

…llowable U/s. 36(1) (li) i.e. the borrowings should be for the purpose of business CIT VS. Associated Fibre & Rubber Industries Pvt. Ltd [236 IT 471]. Thereafter, Hon'ble Bombay High Court applying the decision of Calico Dyeing & Printing works Vs CIT [(1958) 34 ITR 265] held in CIT v/s. Lokhandwala Constructions India Ltd. [2003] 260 ITR 0579] that ..while adjudicating the claim for deduction u/s. 36(1) (li) of the Act, the nature of Expenses - whether the expenses was on capital account or on revenue account – was & irrelevant as the section itself says that interest paid by the appellant on the capital borrowe…

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