https://www.taxtmi.com/caselaws?id=16198 The dominant issue was whether interest on borrowings used to acquire shares, purchased with the primary intention of obtaining controlling interest, was deductible under s.57(iii) as expenditure incurred "wholly and exclusively" for earning income under the head "Income from other sources". The HC held that s.57(iii) requires the dominant and immediate purpose of the expenditure to be the earning of such income (e.g., dividends); where the expenditure is incurred to acquire or protect control, it falls outside s.57(iii), consistent with prior HC and other HC authority distinguishing control-related outlays from income-earning expenditure. Consequently, the interest was not allowable as a deduction, and the reference was answered in favour of the Revenue. en-us Tue, 20 Apr 1999 00:00:00 +0530 Fri, 19 Dec 2025 16:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16198 The dominant issue was whether interest on borrowings used to acquire shares, purchased with the primary intention of obtaining controlling interest, was deductible under s.57(iii) as expenditure incurred "wholly and exclusively" for earning income under the head "Income from other sources". The HC held that s.57(iii) requires the dominant and immediate purpose of the expenditure to be the earning of such income (e.g., dividends); where the expenditure is incurred to acquire or protect control, it falls outside s.57(iii), consistent with prior HC and other HC authority distinguishing control-related outlays from income-earning expenditure. Consequently, the interest was not allowable as a deduction, and the reference was answered in favour of the Revenue. Case-Laws Income Tax Tue, 20 Apr 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16198