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<h1>Broken period interest on purchase of securities as stock-in-trade upheld as deductible, SLP dismissed for unexplained delay.</h1> Broken period interest paid on purchase of securities held as stock-in-trade is treated as an allowable business expenditure and deductible in computing ... Broken period interest paid on purchase of securities - entitlement to claim deduction of interest paid on purchase of securities constituting stock for the broken period till the date of acquisition in terms of Section 37 - delay of 959 days in filing the Special Leave Petition As decided by HC [2023 (1) TMI 1438 - TELANGANA HIGH COURT] Tribunal has correctly held that the respondent had purchased securities to hold them as stock-in-trade. Therefore, interest paid on such securities would be an allowable deduction. HELD THAT:-There is a gross delay of 959 days in filing the Special Leave Petition which has not been satisfactorily explained by the petitioner. Even otherwise, we see no reason to interfere with the impugned order passed by the High Court. Issues: (i) Whether the Special Leave Petition should be dismissed on account of unexplained delay in filing. (ii) Whether interference with the impugned High Court order is warranted on merits.Issue (i): Whether the Special Leave Petition should be dismissed on account of unexplained delay in filing.Analysis: There was a gross unexplained delay of 959 days in filing the Special Leave Petition; this delay was not satisfactorily explained and was relied upon as a ground for refusal of relief.Conclusion: The Petition is dismissed on the ground of delay.Issue (ii): Whether interference with the impugned High Court order is warranted on merits.Analysis: Independent review of the impugned High Court order shows no reason to interfere; the petition was rejected both on delay and on merits.Conclusion: No interference is warranted; the Petition is dismissed on merits.Final Conclusion: The Special Leave Petition is dismissed on the grounds of delay and on merits; pending applications, if any, stand disposed of.Ratio Decidendi: An unexplained and substantial delay in filing a Special Leave Petition warrants dismissal, and where no reason for interference with the impugned order is found, the petition may be dismissed on merits as well.
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