<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>2025 (1) TMI 1750 - ITAT MUMBAI</title>
    <link>https://www.taxtmi.com/caselaws?id=466101</link>
    <description>Allowability of interest under section 36(1)(iii) requires the assessee to prove that borrowed capital was raised wholly and exclusively for business, demonstrating a direct and proximate nexus between the borrowing and business activities; where borrowings refinance earlier liabilities the assessee must establish end-use, commercial rationale, absence of diversion to non-business investments, and support by contemporaneous records, failing which deduction cannot be allowed. The assessing officer is directed to verify purpose, utilisation, nexus and commercial expediency and pass a speaking order after hearing. Disallowance under section 14A read with rule 8D is limited to exempt income and no further disallowance is warranted where a suo motu adjustment has been made.</description>
    <language>en-us</language>
    <pubDate>Tue, 21 Jan 2025 00:00:00 +0530</pubDate>
    <lastBuildDate>Fri, 23 Jan 2026 19:18:28 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=880971" rel="self" type="application/rss+xml"/>
    <item>
      <title>2025 (1) TMI 1750 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=466101</link>
      <description>Allowability of interest under section 36(1)(iii) requires the assessee to prove that borrowed capital was raised wholly and exclusively for business, demonstrating a direct and proximate nexus between the borrowing and business activities; where borrowings refinance earlier liabilities the assessee must establish end-use, commercial rationale, absence of diversion to non-business investments, and support by contemporaneous records, failing which deduction cannot be allowed. The assessing officer is directed to verify purpose, utilisation, nexus and commercial expediency and pass a speaking order after hearing. Disallowance under section 14A read with rule 8D is limited to exempt income and no further disallowance is warranted where a suo motu adjustment has been made.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Tue, 21 Jan 2025 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=466101</guid>
    </item>
  </channel>
</rss>