The Court observed that in the instant case, the claim of the assessee for the expenditure and the deduction of write-off being the amount lent to MMC including interest due and advances for purchase of machinery given in the course of dealing with MMC was disallowed by the authorities under the Act for the preceding year i.e. the year 1989-90. The assessee filed an appeal viz. ITXA No.626 of 2002 which was decided by a Division Bench of this Court vide order dated 9th June 2023 in Mahindra & Mahindra Ltd. vs. Commissioner of Income Tax. The Hon Court agreed with the view taken by Division Bench of this Court in assessee’s own case in Mahindra & Mahindra Ltd. v. CIT (Order dated 9th June 2023) for the following reasons. Admittedly, MMC is a subsidiary of the assessee and assessee holds 27% equity capital of MMC since its incorporation. The assessee promoted the MMC on 15th May 1946. From the date of incorporation of the assessee, it was the managing agent of the MMC and the assessee has acted as a managing agent till 1974 when the Companies Act, 1974 abolished the Managing Agency System. However, due to severe recession in the textile industry, MMC started making losses. Thereupon, the MMC was wound-up. The assessee, in its board meeting held on 27th March 1989 agreed to incur expenditure for maintenance of MMC. Thereafter on 10th July 1990 the Board of Directors of the assessee agreed to resolve the dispute to meet the expenditure till the affairs of MMC were wound-up. The Board of Directors approved the expenditure made by the assessee in the previous relevant Assessment Year 1990-91. The assessee held substantial portion of equity capital of MMC and MMC was regarded in public and official circles as a Mahindra Company. The assessee, in order to protect and preserve the assets and to protect the value of goodwill attached to the assessee by various sections of the society and on the ground of commercial expediency, incurred expenditure, which is permissible as deduction.(AY. 1990 -91  )