Allowing the appeal of the assessee the Court held that ;the non-convertible debentures and secured premium notes were both freely transferable. If the promoters’ secured premium notes holders and the banks and financial institutions therefore, traded in such secured premium notes, that would not indicate any colourable device of tax planning. Mere early redemption also would not be enough to hold that from the inception there was a device created by the company to defeat the Revenue’s interests. The interest was deductible.In order to claim deduction under section 36(1)(iii) of the Income-tax Act, 1961 , all that is necessary is that the money, i. e., capital, must have been borrowed by the assessee, that it must have been borrowed for the purpose of business and lastly, that the assessee must have paid interest on the borrowed amount. All that is germane is whether the borrowing was, or was not, for the purpose of the business. The provision makes no distinction between money borrowed to acquire a capital asset or a revenue asset.( AY.1999-2000)