Judgment :- (CHITRA VENKATARAMAN,J.) 1. Following are the substantial questions of law raised by the Revenue in respect of the assessment years 1990-1991 and 1992-1993: "1. Whether in the facts and circumstances of the case, the Tribunal was right in holding that the interest on the borrowed money utilised for the investment in shares cannot be set off against the dividend income under Section 80 M of the Income Tax Act? 2. Whether in the facts and circumstances of the case, the Tribunal was right in holding that because the investments in shares were made as per Reserve Bank guidelines, it should be treated as a business activity?" 2. Learned counsel appearing for the assessee before this Court had fairly pointed out that the said issues are covered by the decision of this Court reported in Commissioner of Income Tax Vs. Balika Finance Co. Ltd. (2008(299) ITR 421 (Mad.), to which one of us is a party, wherein it had been wsheld that the deduction under 80M of the Income Tax Act, 1961, has to be worked out after taking into account the interest on the borrowed capital for the purpose of computation. 3. Applying the said decision to the facts of the cases, the questions are answered in favour of the Revenue. The Tax Case appeals are allowed. No costs.