Dismissing the appeal of the revenue the Court held that , even though the foreign loan was utilised by the assessee to repay the loan taken from Indian entity towards its working capital requirement, the purpose of section 10(15)(iv)(f) of industrial development stood satisfied. The words in the provision are not “for industrial development”, but “having regard to the need for industrial development in India” and were wide enough to cover within their ambit and scope even the indirect utilisation of the funds for industrial development in India.( AY.2000-01)
CIT v. Seven Seas Distillery (Pvt.) Ltd. (2020)422 ITR 229 / 185 DTR 105/ 312 CTR 272 / 271 Taxman 229(Mad) (HC)
S. 10(15) :Interest payable- Interest on Foreign currency loan Specified securities – Loan utilised for repayment of domestic loan taken towards working capital- Exemption cannot be denied . S.10(15)(iv)(f)