SANGEETHAPRIYA,SALEM vs. DCIT, CIRCLE 1(1), SALEM, SALEM

ITA 154/CHNY/2026Status: DisposedITAT Chennai24 August 2026AY 2020-217 pages
AI SummaryRemanded

What were the facts?

The assessee claimed interest on borrowings as a business expenditure. The Assessing Officer disallowed the interest, holding that the borrowings were not utilized for business purposes and the assessee failed to prove their genuineness. The CIT(A) confirmed this disallowance.

What did the Tribunal hold?

The Tribunal held that the core issue was whether the borrowings were utilized for investment in the partnership firm. This required factual verification by the Assessing Officer.

What were the issues?

Whether the interest paid on borrowings utilized for investment in a partnership firm is allowable as a business deduction, and whether the assessee proved the genuineness and utilization of such borrowings for business purposes.

Which sections of the Income-tax Act were involved?

Section 28(1),Section 147,Section 144,Section 144B,Section 148,Section 148A,Section 250,Section 139

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, CHENNAI BENCHES, CHENNAI

Pronounced: 24.08.2026

PER INTURI RAMA RAO, ACCOUNTANT MEMBER :

This appeal filed by the Assessee directed against the order of the Learned Commissioner of Income Tax(Appeals)[NFAC], dated 24.12.2025 passed u/s.250 of the Income Tax Act, 1961 for the Assessment Year 2020-21. 1 SANGEETHAPRIYA

2.

The Assessee raised the following grounds of appeal : “1) Learned Commissioner of Income-tax (Appeals) is not justified in confirming disallowance of interest of Rs.52,95,280 paid on borrowals made from 01.04.2009 and util

The order continues below.

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