Sec. 41(1) additions made as assessee failed to explain reasons for non-payment of liabilities in no

IT : Where interest or borrowed capital to invest in shares, for period prior to financial year 1997-98, was claimed and allowed as revenue expenditure, it could not transform its character from financial year 1997-98 onwards to become a capital cost without any change in underlying facts, and hence, same could not be treated as cost of acquisition and/or improvement in computation of capital gains