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    <title>2025 (2) TMI 1856 - ITAT AGRA</title>
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    <description>Interest on borrowings used to fund a partner&#039;s capital contribution in a partnership firm was held not disallowable merely because the borrowing cost exceeded the return from the firm. In the absence of a finding that the funds were used for non-business purposes or that commercial expediency was lacking, the higher interest rate alone did not justify disallowance. The resulting business loss was also held eligible for set-off against income from other heads, as no statutory bar prevented adjustment of a non-capital loss under the applicable set-off rules. The contrary additions were deleted and full relief was granted to the assessee.</description>
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