Strategic investments in group companies treated as business activity, allowing expense deductions and loss set-off against interest income.

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....Whether the assessee's investments in group/subsidiary companies constituted "business" so as to allow related expenditure and consequent set-off of loss was the dominant issue. The Tribunal held that the assessee's main object was to make strategic investments in such companies, and the investments made were in furtherance of that object; hence, the activity amounted to business within s.2(13) and the expenditure was incidental thereto, warranting allowance as business expenditure. Having accepted the resultant current-year business loss, the Tribunal directed that it be set off against interest income assessed under "Income from other sources" in accordance with s.71, and allowed the appeal. - ITAT....