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TMI Blog1990 (9) TMI 5X X X X Extracts X X X X X X X X Extracts X X X X ..... d Case No. 33 of 1973. The question which arose for consideration was : "Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the following two sums were admissible as deductions under sections 19, 20 and 37 of the Income-tax Act, 1961 : (a) Rs. 58,568, interest accrued on securities taken over by the assessee-bank from Jayalakshmi Bank Ltd. a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s was deductible under sections 19, 20 and 37. The High Court, on a reference at the instance of the Revenue, held that the amounts received by the assessee as interest on securities were taxable under section 18 of the Act. The High Court referred to CIR v. Pilcher [1949] 31 TC 314 (CA) and other cases, and observed that the amounts expended by the assessee for the purchase of securities were in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... securities, the price paid for them was in the nature of a capital outlay and no part of it can be set off as expenditure against income accruing on those securities. Subsequently, when these securities yielded income by way of interest, such income attracted section 18. A claim for deduction can be sustained only when the assessee is in position to show that any reasonable expenditure had been ..... X X X X Extracts X X X X X X X X Extracts X X X X
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