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    <title>2022 (12) TMI 160 - ITAT JAIPUR</title>
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    <description>Where an assessee has sufficient interest-free funds, and the Revenue cannot show a direct nexus between borrowed funds and investments or advances made through a mixed overdraft account, interest disallowance is not sustainable; the mixed-funds presumption applies and the outgo is treated as coming from interest-free sources. A scholarship liability under a business promotion scheme was held to have crystallised when eligible students were selected and the amount quantified, so it was an ascertained liability rather than a contingent provision. Expenditure on electricity connection, internet networking and name transfer fee was treated as revenue in nature, while boundary wall expenditure was capital expenditure eligible for depreciation and regularisation-related expenditure was disallowed as a penalty for unauthorised construction.</description>
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      <link>https://www.taxtmi.com/caselaws?id=431043</link>
      <description>Where an assessee has sufficient interest-free funds, and the Revenue cannot show a direct nexus between borrowed funds and investments or advances made through a mixed overdraft account, interest disallowance is not sustainable; the mixed-funds presumption applies and the outgo is treated as coming from interest-free sources. A scholarship liability under a business promotion scheme was held to have crystallised when eligible students were selected and the amount quantified, so it was an ascertained liability rather than a contingent provision. Expenditure on electricity connection, internet networking and name transfer fee was treated as revenue in nature, while boundary wall expenditure was capital expenditure eligible for depreciation and regularisation-related expenditure was disallowed as a penalty for unauthorised construction.</description>
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      <pubDate>Thu, 04 Aug 2022 00:00:00 +0530</pubDate>
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