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    <title>2025 (8) TMI 1285 - BOMBAY HIGH COURT</title>
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    <description>Whether interest paid on bank loans used to fund advances to sister concerns is deductible against interest received hinges on whether lending constituted the assessee&#039;s business and when business commenced. The court found that commencement includes preparatory stages and that lending to group concerns was within the company&#039;s objects in the memorandum and consistent with subsequent assessment years; therefore interest paid is allowable as a deduction against interest income. The tribunal&#039;s finding that such lending was fortuitous was set aside to align the 1992-93 assessment with later years where identical transactions were treated as business income and related interest expense was allowed.</description>
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      <description>Whether interest paid on bank loans used to fund advances to sister concerns is deductible against interest received hinges on whether lending constituted the assessee&#039;s business and when business commenced. The court found that commencement includes preparatory stages and that lending to group concerns was within the company&#039;s objects in the memorandum and consistent with subsequent assessment years; therefore interest paid is allowable as a deduction against interest income. The tribunal&#039;s finding that such lending was fortuitous was set aside to align the 1992-93 assessment with later years where identical transactions were treated as business income and related interest expense was allowed.</description>
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