Dismissing the appeal of the revenue the Court held that argument of Revenue that loan taken from agents/ dealers is on revenue account or that on waiver of the loan, its character undergoes a change and it becomes on revenue account is not correct. S. 28(iv) & 41(1) cannot apply if the loan is on capital account and the assessee has never claimed any deduction therefor in the past (Solid Containers Ltd v. Dy CIT ( 2009)  308 ITR 417 (Bom) (HC)  distinguished, CIT v.  Mahindra and Mahindra Ltd (2018) 404 ITR 1 (SC) followed).( ITA No. 896 of 2017, dt. 25.09.2019) (AY. 2009-10)