Allowable deduction of interest paid on the borrowings - Section...

Allowable deduction of interest paid on the borrowings - Section 14A and Section 36(1)(iii) - Exempted dividend income - Based on the discussions and findings, the court dismissed the appeal, affirming the decision of the ITAT. It upheld the disallowance of the interest expense, considering the provisions of Section 14A and the principles established in the Maxopp Investment Ltd. case. The expenditure incurred on interest paid on borrowed funds for investment in shares of the two companies, from which dividend income does not form part of the total income, was held to be hit by Section 14A of the Act and not allowable as deduction.