https://www.taxtmi.com/caselaws?id=178236 Disallowance of interest is upheld where borrowed funds were not originally borrowed for and actually utilised in the money lending business; historical use governs attribution of borrowed capital, and advances made by the firm to partners for personal purposes, interest free and not used in the business, cannot be treated as business loans, so the firm's interest deduction is disallowed. Correspondingly, individual partners cannot claim the disallowed interest as a deduction because they did not themselves borrow the sums nor show that withdrawals were capital borrowed for carrying on their separate business activities; partners' claims are rejected. en-us Wed, 17 Feb 1965 00:00:00 +0530 Sat, 30 Jan 2016 17:00:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178236 Disallowance of interest is upheld where borrowed funds were not originally borrowed for and actually utilised in the money lending business; historical use governs attribution of borrowed capital, and advances made by the firm to partners for personal purposes, interest free and not used in the business, cannot be treated as business loans, so the firm's interest deduction is disallowed. Correspondingly, individual partners cannot claim the disallowed interest as a deduction because they did not themselves borrow the sums nor show that withdrawals were capital borrowed for carrying on their separate business activities; partners' claims are rejected. Case-Laws Income Tax Wed, 17 Feb 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178236