1984 (8) TMI 127

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....are transfer fee of Rs. 4350 as expenditure deductible under s. 57 (iii) and thereby allowing deduction under s. 80M with reference to net dividends income. CIT (A) thus had directed the ITO to allow deduction under s. 80M with reference to net dividends income CIT (A) thus had directed the ITO to allow deduction under s. 80M with reference to gross amount of dividends of Rs. 2,10,389. 2. The a....

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....erest paid on borrowings utilised for an acquisition of shares as also share transfer fee were business expenditure and were not deductible out of dividend income. 4. The Revenue is in appeal before us and stresses that after the amendment of s. 12 of IT Act, 1922 by Finance Act, 1956 (whereby the dividends were directed to be assessable under the head 'income from other sources'), the dividend....

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....gents and the High Court at p. 238 observed that though dividend income fall under the specific had of 'Income from other sources', for the purposes other then the computation of income the commercial character of that income can be taken into account fro determining whether borrowing of which interest was paid was for the purpose of business. They thus held that the payment by the said assessee o....