https://www.taxtmi.com/caselaws?id=6988 The first proviso to section 8 of the Income-tax Act, 1922, with its Explanations, applied only where actual expenditure on realising interest or a borrowing cost for investment in securities existed; it could not create a fiction of expenditure or borrowing where none had been incurred. On the facts stated, that proviso did not apply and the assessee succeeded on that point. Securities issued by the then Mysore Durbar were also held to fall outside section 8, because the provision was confined to interest on securities of the Central Government or a State Government of the relevant kind. The disallowance was therefore excluded and the reference went against the revenue. en-us Wed, 18 Jan 1967 00:00:00 +0530 Sat, 07 Feb 2009 13:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6988 The first proviso to section 8 of the Income-tax Act, 1922, with its Explanations, applied only where actual expenditure on realising interest or a borrowing cost for investment in securities existed; it could not create a fiction of expenditure or borrowing where none had been incurred. On the facts stated, that proviso did not apply and the assessee succeeded on that point. Securities issued by the then Mysore Durbar were also held to fall outside section 8, because the provision was confined to interest on securities of the Central Government or a State Government of the relevant kind. The disallowance was therefore excluded and the reference went against the revenue. Case-Laws Income Tax Wed, 18 Jan 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6988