https://www.taxtmi.com/caselaws?id=470174 Borrowing costs attributable to funds transferred from a non-eligible unit to a section 80-IC eligible undertaking may be allocated proportionately according to the period of fund utilisation, reducing the eligible undertaking's deduction. Such allocation is distinct from disallowance of interest for failure to deduct tax at source; the tax-deduction-at-source disallowance operates independently and does not create double disallowance. In contrast, flat-rate disallowances of telephone, travelling and conveyance expenses without stated reasons or identified defects are arbitrary and unsustainable. The notes distinguish reasoned allocation and statutory tax-deduction disallowance from unsupported estimated expense disallowances. en-us Fri, 03 Jul 2015 00:00:00 +0530 Sat, 18 Jul 2026 13:22:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470174 Borrowing costs attributable to funds transferred from a non-eligible unit to a section 80-IC eligible undertaking may be allocated proportionately according to the period of fund utilisation, reducing the eligible undertaking's deduction. Such allocation is distinct from disallowance of interest for failure to deduct tax at source; the tax-deduction-at-source disallowance operates independently and does not create double disallowance. In contrast, flat-rate disallowances of telephone, travelling and conveyance expenses without stated reasons or identified defects are arbitrary and unsustainable. The notes distinguish reasoned allocation and statutory tax-deduction disallowance from unsupported estimated expense disallowances. Case-Laws Income Tax Fri, 03 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470174