Judgment :- (Appeals under Section 260A of the Income Tax Act, 1961 against the common order of the Income Tax Appellate Tribunal, Madras 'A' Bench dated 9.1.2003 in ITA Nos.665 and 687/1993 for the assessment year 1989-90.) P.D. Dinakaran, J. The above tax case appeal is directed against the order of the Income-tax Appellate Tribunal in ITA Nos.665 and 687/1993 dated 9.1.2003. 2. The Revenue is the appellant. The assessment year involved is 1989-90. The assessing officer, on completing assessment, disallowed the claim of the assessee in respect of guarantee commission paid to the directors under section 40(A)(2), maintenance and repair cost of the vehicle, equipments and buildings and interest on borrowed funds which were lent to sister concerns as interest free. Aggrieved by the said order of the assessing officer, the assessee preferred an appeal before the Commissioner of Income-tax (Appeals), while allowing the appeal in respect of the first and second issue in favour of the assessee, decided the third issue in favour of the revenue. Aggrieved by the same, both, the assessee and the revenue took appeals before the Income-tax Appellate Tribunal and the Tribunal decided all the issues in favour of the assessee. 3. Aggrieved by the same, the Revenue has preferred the above appeals raising the following substantial question of law: "1. Whether in the facts and circumstances of the case, the Tribunal was right in holding that guarantee commission paid by a closely held company to the directors who are related is allowable as deduction? 2. Whether in the facts and circumstances of the case, the Tribunal was right in holding that maintenance and repair cost of the vehicles equipments and buildings are allowable when the assessee had not submitted details of the expenditure? 3. Whether in the facts and circumstances of the case, the Tribunal was right in deleting the addition of interest paid on borrowed funds by the assessee on the amounts advanced to sister concern as interest free? " 4.1. With regard to the first issue, Mrs.Pushya Sitaraman, learned senior standing counsel appearing for the Revenue, fairly submits that the issue is already covered against the Revenue by several decisions of Apex Court and of High Courts. 4.2. " 4.1. With regard to the first issue, Mrs.Pushya Sitaraman, learned senior standing counsel appearing for the Revenue, fairly submits that the issue is already covered against the Revenue by several decisions of Apex Court and of High Courts. 4.2. The Apex Court, in Commissioner of Income-Tax v. Luxmi Devi Sugar Mills P. Ltd [(1991) 188 I.T.R. 41], held that the sum paid by the assessee as interest on arrears of can purchase tax was deductible. Further, the view taken by the Andhra Pradesh High Court in Commissioner of Income-Tax (Addl.) v. Akkamamba Textiles [(1979) 117 I.T.R. 294] that guarantee commission paid by the assessee to the banker and the insurance company for ensuring deferred payment of the purchase consideration of machinery was an admissible deduction under section 37 of the Income-tax Act, 1961 was affirmed by the Apex Court, on an appeal by the Revenue, reported in (1997) 227 I.T.R. 464]. A similar view was also taken by this Court in Sivakami Mills Ltd. v. C.I.T., [(1979) 120 I.T.R. 211], wherein it has been held that the guarantee commission paid to the bank was a revenue expenditure and therefore, was an allowable deduction in computing the total income of the assessee, which was also affirmed by the Apex Court, on appeal by the Revenue, reported in (1997) 227 I.T.R. 465. 4.3. Following the above decisions, the Delhi High Court in Mahalakshmi Sugar Mills Co. Ltd. v. Commissioner of Income-Tax [(2001) 252 I.T.R. 691], held that the guarantee commission paid to the director for standing guarantor for the loan taken by the assessee from the bank was deductible. 4.4. In view of the above settled propositions of law, we find no question of law to be considered in this appeal with regard to the first issue. 5. With regard to the second and third issues, viz., allowance of maintenance and repair cost of the vehicles equipments and buildings and deletion of the addition of interest paid on borrowed funds on the amounts advance to the sister concern as interest free, we find that the findings rendered by the Tribunal with regard to the issues are findings of fact and hence, no question of law arises for consideration with regard to the same in this appeal. 6. Accordingly, finding no question of law much less substantial question of law arises for consideration, we dismiss the above Tax Case Appeals.