Issues involved: The appeal challenges the judgment and order passed by the Income-tax Appellate Tribunal regarding deductions claimed by a public limited company for the assessment year 1992-93, particularly under section 36(1)(iii) and section 37(4) of the Income-tax Act, 1961.
Question (a): The High Court declined to consider whether interest already capitalized in the books can be claimed as revenue expenditure for taxation as this question was not raised before the Tribunal, and the High Court can only determine issues not decided by the Tribunal as per section 260A(6)(a).
Questions (b) and (h): The Tribunal concluded that the fertilizer unit should be treated as part of the company, allowing deductions under section 36(1)(iii) based on unity of control, interdependence, and interconnection between the businesses, as supported by various judgments. The High Court agreed with the Tribunal's findings and did not find a legal question warranting further adjudication.
Question (f): The Tribunal allowed the interest attributable to borrowings for investments in tax-free bonds under section 36(1)(iii) based on evidence that the investments were made in the course of business, following precedents. The High Court found no substantial legal issue in this matter.
Question (j): The Tribunal partially allowed expenses incurred for maintenance of guest houses under section 37(4) based on a previous judgment, as the specific contention against disallowance was not pressed. The High Court found no grounds for further consideration and dismissed the appeal without costs.
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