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    <title>2026 (1) TMI 679 - ITAT MUMBAI</title>
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    <description>Classification of interest receipts as business income versus income from other sources was examined, applying the definition of business and the profit-motive and risk tests; the income was held to be business income because lending was systematic, profit driven and involved commercial risk, and this outcome was upheld. The asserted consistency defence was rejected. Consequentially, failure to deduct tax at source on interest attracted disallowance under tax compliance rules, and because business receipts exceeded threshold, the assessee was required to obtain a tax audit; both disallowance and audit requirement were sustained.</description>
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    <pubDate>Wed, 17 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 679 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=784923</link>
      <description>Classification of interest receipts as business income versus income from other sources was examined, applying the definition of business and the profit-motive and risk tests; the income was held to be business income because lending was systematic, profit driven and involved commercial risk, and this outcome was upheld. The asserted consistency defence was rejected. Consequentially, failure to deduct tax at source on interest attracted disallowance under tax compliance rules, and because business receipts exceeded threshold, the assessee was required to obtain a tax audit; both disallowance and audit requirement were sustained.</description>
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      <pubDate>Wed, 17 Dec 2025 00:00:00 +0530</pubDate>
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