https://www.taxtmi.com/caselaws?id=182284 Disallowance under section 14A was considered unwarranted for interest expenditure where the assessee's own funds exceeded the investment yielding exempt dividend income and no diversion of borrowed funds was shown; only a limited administrative disallowance was sustained, and the section 115JB adjustment was confined accordingly. Corporate debt restructuring fees paid to financial consultants were treated as revenue expenditure under section 37(1) because they were incurred in the course of business to restructure borrowings and reduce interest burden. The principal amount of loan waived under the restructuring arrangement was treated as remission of capital liability and not taxable as income. The section 115JB book-profit computation was held to track only the legally sustainable section 14A disallowance. en-us Tue, 25 Jun 2013 00:00:00 +0530 Wed, 10 Sep 2025 15:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=182284 Disallowance under section 14A was considered unwarranted for interest expenditure where the assessee's own funds exceeded the investment yielding exempt dividend income and no diversion of borrowed funds was shown; only a limited administrative disallowance was sustained, and the section 115JB adjustment was confined accordingly. Corporate debt restructuring fees paid to financial consultants were treated as revenue expenditure under section 37(1) because they were incurred in the course of business to restructure borrowings and reduce interest burden. The principal amount of loan waived under the restructuring arrangement was treated as remission of capital liability and not taxable as income. The section 115JB book-profit computation was held to track only the legally sustainable section 14A disallowance. Case-Laws Income Tax Tue, 25 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=182284