COMMISSIONER OF INCOME TAX Vs. MODI INDUSTRIES LTD.

JUDGEMENT

(1.) THE following three questions of law have been referred for our opinion under s. 256(1) of the IT Act, 1961, in RA No. 943/Del/1983 in ITA No. 771/Del/1982 relevant for the asst. yr. 1971 -72 :

(2.) IT appears from the record that the assessee had borrowed some money which was employed as capital in its unit. The assessee claimed deduction on this amount on the basis of r. 19A(3) of the IT Rules, 1962 which came into force on

(3.) THE ITO denied the deduction.