https://www.taxtmi.com/caselaws?id=22153 HC held that for deduction of interest under section 36(1)(iii), the assessee bears the burden to prove that investments or advances to its subsidiary were made out of its own funds and not out of borrowed funds. On facts, the Tribunal found that borrowed funds were used, and this factual inference was upheld. The HC distinguished earlier authority on functional and capitalist control over subsidiaries, noting that in this case the subsidiary had agreed to pay interest, rendering those principles inapplicable. Consequently, the assessee was not entitled to the claimed interest deduction, and the reference was answered in favour of the Revenue. en-us Fri, 04 Oct 1991 00:00:00 +0530 Mon, 08 Dec 2025 18:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=22153 HC held that for deduction of interest under section 36(1)(iii), the assessee bears the burden to prove that investments or advances to its subsidiary were made out of its own funds and not out of borrowed funds. On facts, the Tribunal found that borrowed funds were used, and this factual inference was upheld. The HC distinguished earlier authority on functional and capitalist control over subsidiaries, noting that in this case the subsidiary had agreed to pay interest, rendering those principles inapplicable. Consequently, the assessee was not entitled to the claimed interest deduction, and the reference was answered in favour of the Revenue. Case-Laws Income Tax Fri, 04 Oct 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=22153