JUDGMENT:

KAPADIA, J. -- For the sake of convenience we state the facts occurring in Civil Appeal Nos.3952-55 of 2002 Dy. Commr. of Income Tax, Ahmedabad v. M/s. Core Health Care Ltd.

2. These civil appeals are directed against judgment and order dated 25.4.01 delivered by Gujarat High Court in Tax Appeal Nos.449 and 450 of 2000 and in Civil Application Nos.53 and 54 of 2001 whereby the Department's appeals, under Section 260A of the Income-tax Act, 1961, stood dismissed.

3. On 31.12.92 assessee filed its return of income for A.Y. 1992-93 declaring "nil" income. Later on the assessee filed a revised return on 6.8.93 declaring a loss of Rs.1,11,68,543/-. Assessee-company is engaged in the business of manufacturing and sale of intravenous solutions. For the assessment year under consideration assessee claimed deduction towards expenses aggregating to Rs.2,12,05,459/- which included interest on borrowings of Rs.1,56,76,000/-. During the assessment year under consideration assessee had installed new machinery. The A.O. vide assessment order dated 30.3.95 disallowed the amount of Rs.1,56,76,000/- placing reliance on the judgment of this C