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9. Aggrieved by the reversal of disallowance of interest expense claimed under section 36(1)(iii), the Revenue has preferred appeal before this Tribunal this time.

10. Ld. CIT Departmental Representative (DR) vehemently supported the order of the Assessing Officer giving rise to the present controversy and submitted that the CIT(A) in the second round of proceedings has misdirected itself in law in coming to a wrongful conclusion towards admissibility of interest expenditure. The Ld. CIT DR referred to the Assessment Order and submitted that it is the consistent position of the ITA Nos.1733 to 1737/Ahd/2014 assessee that the captive power plant is under progress and has not been completed or put to use till the end of the various assessment years in question. It was thereafter contended that the power plant for which the borrowings, giving rise to the interest expenses were made, were not connected with the existing pharmaceutical business of the assessee. In this situation, the interest costs attributable to the power plant unconnected to the existing business is required to be capitalised as rightly done by the Assessing Officer. Ld. CIT DR thereafter insisted that in view of the undisputed fact that the assessee company had intended to divest its investment made in the power plant, the interest attributable to the set up of power plant cannot be set off against the income arising from pharmaceutical operations. It was vehemently submitted that the captive power plant was entirely a new line of business which was only in the process of being set up and thus interest attributable to such a new activity cannot be accepted as permissible deduction within the ambit and scope of section 36(1)(iii) in view of the decision of the Hon'ble Supreme Court in the case of Chellapalli Sugar Mills (supra). Ld. CIT DR thus forcefully contend that the CIT(A) has wrongly appreciated the facts while coming to the conclusion that power plant is only an extension of the existing business. Ld. CIT DR thereafter contended that assessee's reliance in its own case as reported in 298 ITR 94 is of no assistance as the facts in that case are not identical at all. It was contended that in the case before the Hon'ble Supreme Court, it was found as a matter of fact that the expenditure was incurred for the expansion of the existing line of business whereas facts are altogether different in the instant case as pointed out. The CIT DR also contended that the assessee has itself classified the interest expenditure under the head "deferred revenue expenditure" for appreciating treatment in the year of divestment of the investment. It was contended that in such scenario where the interest expenses have been incurred for capital work in progress, the expenditure is without doubt capital in nature. The CIT Departmental Representative accordingly submitted that the CIT(A) has drawn conclusion in favour of ITA Nos.1733 to 1737/Ahd/2014 the assessee on a wrong footing dehors the facts and thus requires to be set aside and the order of the Assessing Officer requires to be upheld.