Interest on capital borrowed for business purposes is...

Interest on capital borrowed for business purposes is deductible, subject to the restriction applicable until an acquired asset is first put to use. Use of land as a storage yard may be established through delivery and transport records, electricity bills and photographs; such evidence requires verification and cannot be rejected without contrary material. Construction reflected as capital work-in-progress on part of the land does not by itself show that the remaining land was not used for business. Where interest-free funds and borrowings form a common pool, investment is presumed to come from interest-free funds unless a direct nexus with interest-bearing borrowings is established.