https://www.taxtmi.com/caselaws?id=39663 Interest on borrowings used to discharge estate duty charged on trust property was treated as deductible under section 12(2) of the Indian Income-tax Act, 1922, because the trustees borrowed to avoid immediate sale of shares and securities and thereby preserve the trust's income source. The borrowing had a direct nexus with earning income, and the interest was expenditure incurred solely for that purpose. Section 74(2) of the Estate Duty Act, 1953, which created a first charge on the movable property, also supported the deduction because the borrowing was used to clear the charge and free the property for income generation. The answer to the referred question was in the affirmative, in favour of the assessee. en-us Wed, 10 Jul 1974 00:00:00 +0530 Thu, 15 Jan 2026 16:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39663 Interest on borrowings used to discharge estate duty charged on trust property was treated as deductible under section 12(2) of the Indian Income-tax Act, 1922, because the trustees borrowed to avoid immediate sale of shares and securities and thereby preserve the trust's income source. The borrowing had a direct nexus with earning income, and the interest was expenditure incurred solely for that purpose. Section 74(2) of the Estate Duty Act, 1953, which created a first charge on the movable property, also supported the deduction because the borrowing was used to clear the charge and free the property for income generation. The answer to the referred question was in the affirmative, in favour of the assessee. Case-Laws Income Tax Wed, 10 Jul 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39663