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    <title>2026 (1) TMI 188 - ITAT DELHI</title>
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    <description>The dominant issue was whether expenditure incurred for holding investments in group companies could be treated as business expenditure, enabling set-off of resulting business loss against interest income under s. 71. The Tribunal held that the assessee&#039;s main object was to make investments in specified companies and the investments were made in furtherance of that object; such investment activity constituted &quot;business&quot; within s. 2(13), and the related expenses were incidental to carrying on that business, warranting deduction. Consequently, the current year business loss arising therefrom was allowable to be set off against income assessed under &quot;Income from other sources&quot; in accordance with s. 71, and the AO was directed to grant the set-off; appeal allowed.</description>
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      <title>2026 (1) TMI 188 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=784432</link>
      <description>The dominant issue was whether expenditure incurred for holding investments in group companies could be treated as business expenditure, enabling set-off of resulting business loss against interest income under s. 71. The Tribunal held that the assessee&#039;s main object was to make investments in specified companies and the investments were made in furtherance of that object; such investment activity constituted &quot;business&quot; within s. 2(13), and the related expenses were incidental to carrying on that business, warranting deduction. Consequently, the current year business loss arising therefrom was allowable to be set off against income assessed under &quot;Income from other sources&quot; in accordance with s. 71, and the AO was directed to grant the set-off; appeal allowed.</description>
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