1991 (3) TMI 108

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....s is the assessee's reference. The assessment year involved is 1967-68. The Tribunal has referred to this court, only one question of law under section 256(1) of the Income-tax Act, 1961. The question reads thus : "Whether, on the facts and in the circumstances of the case, the income of Rs. 12,38,387 being interest received on loans and advances is taxable in law as income from business as con....

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....s, inter alia, on the grounds (i) that the interest paid by the assessee on borrowings was allowed as business expenditure and, therefore, those borrowings must have been used by the assessee for the purpose of its business ; (ii) it inferred from the aforesaid fact that the monies available for advancing loans, thus, had or could have their sources in the assessee's own reserves and surpluses fro....