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    <title>2025 (12) TMI 1328 - ITAT DELHI</title>
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    <description>Proportionate interest on borrowings used for a specific business activity was held deductible under s.36(1)(iii) since it was directly attributable to business use; the Revenue&#039;s challenge was rejected and the allowance upheld. Finance cost on borrowed funds utilised to advance loans to policyholders was held allowable under s.36(1)(iii) because the assessee offered the corresponding interest income and the AO disallowed without reasons or rebuttal; the disallowance was set aside. Indirect common management expenses were held incurred wholly and exclusively for business and directed to be allowed; the Revenue&#039;s disallowance failed. Land development expenditure paid under agreement and supported by bills was allowed as genuine absent contrary evidence; non-production of a vendor on short notice could not justify disallowance. Interest on deposits was allowed where treated as business receipt and AO gave no specific finding; Revenue&#039;s grounds were dismissed.</description>
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    <pubDate>Fri, 27 Jun 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1328 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=783788</link>
      <description>Proportionate interest on borrowings used for a specific business activity was held deductible under s.36(1)(iii) since it was directly attributable to business use; the Revenue&#039;s challenge was rejected and the allowance upheld. Finance cost on borrowed funds utilised to advance loans to policyholders was held allowable under s.36(1)(iii) because the assessee offered the corresponding interest income and the AO disallowed without reasons or rebuttal; the disallowance was set aside. Indirect common management expenses were held incurred wholly and exclusively for business and directed to be allowed; the Revenue&#039;s disallowance failed. Land development expenditure paid under agreement and supported by bills was allowed as genuine absent contrary evidence; non-production of a vendor on short notice could not justify disallowance. Interest on deposits was allowed where treated as business receipt and AO gave no specific finding; Revenue&#039;s grounds were dismissed.</description>
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      <pubDate>Fri, 27 Jun 2025 00:00:00 +0530</pubDate>
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