https://www.taxtmi.com/caselaws?id=784486 Deduction under s.36(1)(viii) was allowed as the taxpayer, a financial corporation, was engaged in long-term financing of projects in new and renewable energy, falling within "development of infrastructure facility" and thus "eligible business"; CBDT approval was not required post 01.04.2000 due to omission of the proviso, and past approvals/departmental acceptance supported eligibility, so the disallowance was reversed. Recharacterisation of various receipts as "income from other sources" was rejected because the interest and fee streams, refunds/write-backs, swap gains, grants surplus, and reversals were inextricably linked to financing operations or taxable under s.41(1), hence assessable as business income. Disallowance under s.14A was deleted for lack of AO's recorded satisfaction and absence of exempt income. Depreciation was allowed on beneficial ownership and consistent allowance. Disallowance for short TDS under s.40(a)(ia) was held inapplicable. en-us Wed, 31 Dec 2025 00:00:00 +0530 Thu, 01 Jan 2026 16:12:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784486 Deduction under s.36(1)(viii) was allowed as the taxpayer, a financial corporation, was engaged in long-term financing of projects in new and renewable energy, falling within "development of infrastructure facility" and thus "eligible business"; CBDT approval was not required post 01.04.2000 due to omission of the proviso, and past approvals/departmental acceptance supported eligibility, so the disallowance was reversed. Recharacterisation of various receipts as "income from other sources" was rejected because the interest and fee streams, refunds/write-backs, swap gains, grants surplus, and reversals were inextricably linked to financing operations or taxable under s.41(1), hence assessable as business income. Disallowance under s.14A was deleted for lack of AO's recorded satisfaction and absence of exempt income. Depreciation was allowed on beneficial ownership and consistent allowance. Disallowance for short TDS under s.40(a)(ia) was held inapplicable. Case-Laws Income Tax Wed, 31 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784486