https://www.taxtmi.com/caselaws?id=751562 Interest disallowance under s.36(1)(iii) for alleged diversion to group concerns was unsustainable because the assessee had sufficient own funds and the secured borrowings were purpose-specific, and the AO failed to establish a nexus between borrowed funds and advances; the disallowance was deleted for both years. Relaunch/publicity expenditure was revenue in nature since it did not create an enduring advantage or expand the profit-making apparatus; one-third deferred claim was allowed and depreciation earlier granted was reversed. Short TDS credit was directed to be granted as per law (statistical purposes). Disallowance under s.14A was held inapplicable if no exempt income was earned; AO to verify and delete accordingly (statistical purposes). Prior-period expenses were allowable on crystallization in the relevant year; disallowance deleted. Late deposit of employees' PF/ESI was disallowed following SC. Payments to foreign agencies were not taxable absent a PE and were not FTS under the DTAAs; s.40(a)(i) disallowance was deleted. en-us Wed, 27 Mar 2024 00:00:00 +0530 Mon, 05 Jan 2026 11:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751562 Interest disallowance under s.36(1)(iii) for alleged diversion to group concerns was unsustainable because the assessee had sufficient own funds and the secured borrowings were purpose-specific, and the AO failed to establish a nexus between borrowed funds and advances; the disallowance was deleted for both years. Relaunch/publicity expenditure was revenue in nature since it did not create an enduring advantage or expand the profit-making apparatus; one-third deferred claim was allowed and depreciation earlier granted was reversed. Short TDS credit was directed to be granted as per law (statistical purposes). Disallowance under s.14A was held inapplicable if no exempt income was earned; AO to verify and delete accordingly (statistical purposes). Prior-period expenses were allowable on crystallization in the relevant year; disallowance deleted. Late deposit of employees' PF/ESI was disallowed following SC. Payments to foreign agencies were not taxable absent a PE and were not FTS under the DTAAs; s.40(a)(i) disallowance was deleted. Case-Laws Income Tax Wed, 27 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751562