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The the issue is relating to payment of interest on borrowed capital The appellate authority and the Tribunal found that the investment made in shares by the assessee by utilising borrowed capital was for strategic business purposes because the companies were promoted as special purpose companies to strengthen and promote its existing business by combining different business segments and, therefore, the claim was fully allowable under Section 36(1)(iii). We also found that the Revenue did not adduce any material to show that the borrowed capital was utilised by the assessee for non-business purposes. The appellate authority, in our considered view, was correct in allowing the claim of the assessee and deleting the disallowance made by the assessing authority.

Shanti Prime Publication Pvt. Ltd.

Section 36(1)(iii) of the Income Tax Act, 1961—Interest on borrowed capital— Claim made by assessee under section 36(1)(iii) was allowed as appellate authority and the Tribunal found that the investment made in shares by the assessee by utilising borrowed capital was for strategic business purposes because the companies were promoted as special purpose companies to strengthen and promote its existing business by combining different business segments and it was also found that the Revenue did not adduce any material to show that the borrowed capital was utilised by the assessee for non-business purposes — CIT vs. Kec international ltd. [2020] 269 TAXMAN 275 (MAD)

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