Penalty under section 271(1)(c) deleted where income was disclosed in section 153A returns and remaining additions were only estimated or computationa...
The Kerala High Court disallowed interest expense claimed by the appellant u/s 36 of the Income Tax Act as it was incurred on a loan used to purchase agricultural land for cultivating tapioca, not for business purposes. The court held that despite the land being shown as a business asset, there was no evidence of its use for business. The land generated agricultural income exempt u/s 10(1), making the interest expense non-deductible u/s 36(iii) due to Section 14A. The decision favored the revenue.
The Kerala High Court disallowed interest expense claimed by the appellant u/s 36 of the Income Tax Act as it was incurred on a loan used to purchase agricultural land for cultivating tapioca, not for business purposes. The court held that despite the land being shown as a business asset, there was no evidence of its use for business. The land generated agricultural income exempt u/s 10(1), making the interest expense non-deductible u/s 36(iii) due to Section 14A. The decision favored the revenue.
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