JUDGMENT

Mrs. Sujata V. Manohar, J.-The appellant is a public limited company. The present appeal filed by it pertains to the accounting year ending June 30, 1967 relevant to the assessment year 1968-69.

2. On December 10, 1966 a public issue of the debentures of the appellant-company was made. The total value of the debentures was Rs. 1.5 crores repayable with interest at the rate of 5-3/4% per annum. The debentures were issued at a discount of 2%, redeemable after 12 years. The issue price of a debenture of Rs. 100/- was Rs. 98/-. The total discount on the issue of Rs. 1.5 crores amounted to Rs. 3 lakhs. For the assessment year 1968-69 the appellant-company wrote off Rs. 12,500/- out of the total discount of Rs. 3 lakhs being the proportionate amount of discount for the period of six months ending with June 30, 1967, taking into account the period of 12 years which was the period of redemption and dividing the discount of Rs. 3 lakhs over the period of 12 years.

3. Earlier the appellant had issued debentures at a discount of 1% redeemable after 10 years. The discount relating to these debentures was being written off periodically. For the assessment year 1968-69 the appellant-compan