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TMI Blog1987 (7) TMI 28X X X X Extracts X X X X X X X X Extracts X X X X ..... 1985, in Income-tax Reference No. 1970 of 177 (sic), involves substantial questions of law and is a fit one for appeal to the Supreme Court. The substantial questions of law are stated to be as follows : "(a) Whether, in a case where an assessee has no available liquid funds at his disposal and borrows money for the purpose of payment of income-tax instead of liquidating his income-yielding asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Addl. CIT [1987] 166 ITR 176, where the Supreme Court affirming the decision of the Gujarat High Court in [1975] 101 ITR 153 has held that interest paid on loans was not an admissible deduction under section 57 of the Income-tax Act, 1961, where amounts were borrowed to pay taxes and annuity deposit and where the assessee derived income from other sources in the shape of interest and dividends. It ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r the purpose of earning income through other sources. The expression purpose of business " appears to be wider in scope than the expression "purpose of earning income". By reason of the above and in view of the fact that a certificate has been already granted on identical questions in M. M. Thapar's case [1978] 114 ITR 331 (Cal), we allow this application. We certify that it is a fit case for a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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