In Hindustan Cocoa Products Ltd. v\/s Commissioner of Income Tax, reported in [1999] 236 ITR 140, this Court observed that the benefit of section 80V would be available to the Assessee if the borrowings were taken for the purpose of payment of tax. In view of the factual findings in the present case that the deposits were primarily taken for the payment of taxes, and which are uncontroverted even before us, we are of the view that the ratio of the judgment of this Court in Hindustan Cocoa Products Ltd. (supra) would sqaurely apply to the facts of the present case. Question (B) really arises on an interpreation of Rule 6D of the Income Tax Rules, 1962 which dealt with expenditure incurred by the Assessee in connection with the travel of an employee. In the present case, the CIT (Appeals) directed the Assessing Officer to recompute disallowance under Rule 6D of the Rules on the basis of the aggregate trips of each employee and not on the basis of each trip undertaken by the said employee. This direction of the CIT (Appeals) was confirmed by the Tribunal. 5. It is common ground before us that even this Question is squarely covered by a judgment of this Court in the case of Commissioner of Income Tax v\/s AOROW India Ltd., reported in [1998] 229 ITR 325.<\/p>\n","protected":false},"excerpt":{"rendered":"
In Hindustan Cocoa Products Ltd. v\/s Commissioner of Income Tax, reported in [1999] 236 ITR 140, this Court observed that the benefit of section 80V would be available to the Assessee if the borrowings were taken for the purpose of …<\/p>\n