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The High Court of Allahabad ruled that loans taken should not be excluded from the assessee's capital for calculating deduction under section 80J of the Income-tax Act, 1961. The case involved M/s. Lohia Machines Pvt. Ltd. and followed a previous Supreme Court decision in Lohia Machines Ltd. v. CIT [1985] 152 ITR 308. The judgment favored the Revenue and went against the assessee.
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