( 1 ) AS both these appeals involve common facts, they have been heard together and are disposed of by this common judgement and order. The dispute between the parties centres round taxability of interest income in hands of the individual assessee and corresponding deduction of liability in hands of the company. The Assessment Year is 1995-1996 and the relevant accounting period is Financial Year 1994-1995 i. e. year ended on 31st March, 1995. The assessment year and the accounting period are same for the individual assessee as well as the company. TAX APPEAL NO. 157 OF 2000

( 2 ) THE following substantial question of law has been formulated at the time of admission of the appeal on 27th September, 2000:"whether, in the facts and circumstances of the case, the ITAT was right in law in holding that the assessee was not entitled to the deduction of interest paid by it on the debentures issued by it ?"

( 3 ) IN this Tax Appeal the payer company is the appellant. The payer company while filing its return of income claimed deduction of the total amount of interest paid on the ground that the interest paid was a revenue expenditure and could not be disallowed as the same wa