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    <title>2019 (7) TMI 929 - ITAT DELHI</title>
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    <description>Borrowing through debentures was supported by documentary evidence, and the finance cost on redemption was held deductible under section 36(1)(iii) because the test is business purpose and actual borrowing, not whether the transaction produced profit or a capital asset. The related gain on redemption of other debentures was treated as business income. On the commercial-area proceeds, contractual material and third-party confirmation showed the assessee was entitled only to the agreed share, so the higher assessed amount was deleted. Notional rent on an unsold property held as stock-in-trade was also deleted, as section 23(1) could not be used to tax hypothetical rental value absent actual letting.</description>
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      <title>2019 (7) TMI 929 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=383233</link>
      <description>Borrowing through debentures was supported by documentary evidence, and the finance cost on redemption was held deductible under section 36(1)(iii) because the test is business purpose and actual borrowing, not whether the transaction produced profit or a capital asset. The related gain on redemption of other debentures was treated as business income. On the commercial-area proceeds, contractual material and third-party confirmation showed the assessee was entitled only to the agreed share, so the higher assessed amount was deleted. Notional rent on an unsold property held as stock-in-trade was also deleted, as section 23(1) could not be used to tax hypothetical rental value absent actual letting.</description>
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