https://www.taxtmi.com/caselaws?id=16919 Whether the assessee qualified as a "financial company" for s.40A(8) was resolved on concurrent factual findings by CIT(A) and the Tribunal that were not perverse; it fell within s.40A(8)(c) and was entitled to the statutory benefit, so the issue was decided for the assessee and against the Revenue. Whether interest on borrowed capital had to be apportioned against dividend income was answered by applying s.36(1)(iii): once borrowing is for business purposes, the application of funds is immaterial, hence the entire interest is deductible under "Profits and gains of business" without apportionment, in favour of the assessee. Whether s.80M relief is on gross or net dividend was governed by binding HC precedent holding it allowable on the gross dividend, in favour of the assessee. en-us Thu, 19 Feb 1998 00:00:00 +0530 Tue, 30 Dec 2025 18:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16919 Whether the assessee qualified as a "financial company" for s.40A(8) was resolved on concurrent factual findings by CIT(A) and the Tribunal that were not perverse; it fell within s.40A(8)(c) and was entitled to the statutory benefit, so the issue was decided for the assessee and against the Revenue. Whether interest on borrowed capital had to be apportioned against dividend income was answered by applying s.36(1)(iii): once borrowing is for business purposes, the application of funds is immaterial, hence the entire interest is deductible under "Profits and gains of business" without apportionment, in favour of the assessee. Whether s.80M relief is on gross or net dividend was governed by binding HC precedent holding it allowable on the gross dividend, in favour of the assessee. Case-Laws Income Tax Thu, 19 Feb 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16919