https://www.taxtmi.com/caselaws?id=800604 Reassessment founded on an audit objection alleging a health and education cess deduction requires verification that the deduction was actually claimed; an unverified factual premise demonstrates non-application of mind and cannot support reopening. Interest on borrowings invested in a subsidiary remains allowable where the investment is commercially expedient and connected with business purpose. Business purpose is not limited to the taxpayer's immediate profit-making activity, and the Revenue cannot replace a prudent businessperson's commercial judgment. Consequently, neither objection supplies a sustainable basis for reassessment. en-us Thu, 01 Oct 2026 00:00:00 +0530 Thu, 08 Oct 2026 08:45:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800604 Reassessment founded on an audit objection alleging a health and education cess deduction requires verification that the deduction was actually claimed; an unverified factual premise demonstrates non-application of mind and cannot support reopening. Interest on borrowings invested in a subsidiary remains allowable where the investment is commercially expedient and connected with business purpose. Business purpose is not limited to the taxpayer's immediate profit-making activity, and the Revenue cannot replace a prudent businessperson's commercial judgment. Consequently, neither objection supplies a sustainable basis for reassessment. Case-Laws Income Tax Thu, 01 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800604