S. H. Kapadia, J. - (1.) Aggrieved by the common judgment dated 29-4-2005 passed by the High Court of Judicature at Madras in Tax Case (Appeal) Nos. 53/2004 etc., the Department has come to this Court by way of a batch of civil appeals. For the sake of convenience, we have set out hereinbelow the facts in the lead case of M/s. Saravana Spinning Mills Pvt. Ltd. (Civil Appeal Nos. 7604-7605/2005).
(2.) In this group of civil appeals we are required to decide the extent and scope of Section 31(i) of the Income-tax Act, 1961 as it stood during the accounting years ending 31-3-1993 and 31-3-1994.
(3.) For this purpose, we quote hereinbe low Section 31, as it stood during the rel evant period : "31. Repairs and insurance of machin ery, plant and furniture. - In respect of re pairs and insurance of machinery, plant or furniture used for the purposes of the busi ness or profession, the following deductions shall be allowed - (i) the amount paid on account of cur rent repairs thereto; (ii) the amount of any premium paid in respect of insurance against risk of damage or destruction thereof.";