1984 (7) TMI 206

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..... commission of Rs. 7,593 to a bank which stood guarantee for the assessee regarding the assessee s machinery purchase on deferred payment basis. The ITO disallowed it as capital expenditure. On the assessee s appeal the Commissioner (A) held that the guarantee commission should be treated as revenue expenditure following the Madras High Court decision in Sivakami Mills Ltd. v CIT (1979) 120 ITR 21 .....

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..... cost of the assets without reducing the cost by the amount of Central subsidy received by the assessee, following the decision of the Special Bench of this Tribunal dated 2nd February, 1981 in I.T.A. Nos. 2899 2971 (Mad.)/1977-78 in the case of Pioneer Match Works v. ITO reported in (1982) 1 SOT 331 (Mad.). We have heard the parties. The department s submission before us is that the Tribunal s .....

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