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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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