Interest on borrowings used to acquire plant, machinery, scrap,...

Interest on borrowings used to acquire plant, machinery, scrap, land and buildings held as current assets for sale in an asset-trading business is revenue expenditure. The proviso to section 36(1)(iii), which restricts interest deduction until an acquired asset is first put to use, does not apply where the assets are acquired solely for resale and are neither intended nor required to be used in manufacturing. Borrowings for buying and selling such assets are for business purposes. Acquisition-related expenses incurred in dealing in current assets for sale are likewise revenue expenditure allowable under section 37(1), rather than capital expenditure.