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    <title>2026 (1) TMI 9 - ITAT PUNE</title>
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    <description>Dispute concerned whether interest accrued on a concessional (&quot;soft&quot;) loan from a State Government was an unascertained liability disallowable under s. 37. The ITAT held that the loan was validly obtained under an agreement stipulating interest and repayment terms, and non-commencement of repayment due to short drawal from the sanctioned amount did not negate accrual. Under the mercantile system, the interest obligation crystallised with time and was therefore an ascertained liability. Relying on HC authority affirmed by the SC, the ITAT directed allowance of deduction for the interest provision, and the appeal was allowed.</description>
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      <title>2026 (1) TMI 9 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=784253</link>
      <description>Dispute concerned whether interest accrued on a concessional (&quot;soft&quot;) loan from a State Government was an unascertained liability disallowable under s. 37. The ITAT held that the loan was validly obtained under an agreement stipulating interest and repayment terms, and non-commencement of repayment due to short drawal from the sanctioned amount did not negate accrual. Under the mercantile system, the interest obligation crystallised with time and was therefore an ascertained liability. Relying on HC authority affirmed by the SC, the ITAT directed allowance of deduction for the interest provision, and the appeal was allowed.</description>
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