Court held that the activity of the assessee of financing existing Indian enterprises for procurement or acquisition of plant, machinery and equipment on lease and hire purchase basis, was an independent transaction or activity being the business of the assessee. The transaction of loan between the assessee and Commonwealth Development Corporation was in the nature of borrowing money by the assessee, which was necessary for carrying on its business of financing. It was not for creation of an asset of the assessee as such or acquisition of an asset from a country outside India for the purpose of its business. In such a scenario, the assessee would be justified in availing of deduction of the entire expenditure or loss suffered by it in connection with such a transaction in terms of section 37 of the Income-tax Act, 1961. The loan was wholly and exclusively used for the purpose of business of financing existing Indian enterprises, who in turn, had to acquire plant, machinery and equipment to be used by them. It was a different matter that they may do so because of the leasing and hire purchase agreement with the assessee. That would be, nevertheless, an activity concerning the business of the assessee. The analysis and the conclusion arrived at by the Tribunal in respect of the claim of the assessee were correct. India Cements ltd. v. CIT [1966] 60 ITR 52 (SC) and Empire Jute Co. Ltd. v. CIT [1980] 124 ITR 1 (SC) applied. Court also observed that  as a result of the entire claim of the assessee to the tune of Rs.3,56,57,727 having been allowed as revenue expenditure, the final assessment order passed by the Assessing Officer for the AY., had to be amended, thereby treating the consequential benefits such as depreciation availed of by the assessee in relation to the stated amount towards exchange fluctuation related to leased assets capitalised (being Rs. 2,46,04,418), as unavailable and non est.  (AY. 1997-98)