How many judgments cite CIT v. Chennai Properties & Investment Ltd.?

77 judgments on BharatTax cite CIT v. Chennai Properties & Investment Ltd. (239 ITR 435), spanning 2017 to 2026.

Which sections of the Income Tax Act does CIT v. Chennai Properties & Investment Ltd. come up under?

It is most often cited in judgments turning on Section 37(1), Section 201(1A), Section 143(3), Section 142(1), Section 69C, Section 143(2).

CIT v. Chennai Properties & Investment Ltd.

239 ITR 435High Court1999#1476 most cited

What is CIT v. Chennai Properties & Investment Ltd. authority for?

Interest paid under section 201(1A) for delay in remitting tax deducted at source is not an allowable business expenditure and cannot be regarded as a compensatory payment. This interest takes its character from the nature of the tax levy, being a direct tax itself.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2017 to 2026.

Also referred to as

CIT v. Chennai Properties & Investment Ltd. · Section 201(1A) · Section 37(1) · interest on delayed TDS · disallowance of interest · business expenditure deduction · compensatory payment · nature of levy · direct tax

Also reported as

105 Taxmann 346

Sections most often in play

Section 37(1)Section 201(1A)Section 143(3)Section 142(1)Section 69C Section 143(2)Section 144 Section 250

Issues it is cited on

section 215 section 256(1)interest under section 201(1a)section 256 section 201(1a)section 40(a)(ii)section 201 eligible business disallowance of interest expenditure section 21 section 37(1)section 220

Judgments citing CIT v. Chennai Properties & Investment Ltd.

Century Construction, Gwalior vs. DCIT/ACIT 1(1), Gwalior

In the result, the appeal of the Assessee is partly allowed

ITA 15/AGR/2026[2018-19]Status: DisposedITAT Agra02 Apr 2026AY 2018-19

Bench: Shri M. Balaganeshcentury Construction, Vs. Dcit/Acit-1(1), 144, Mayur Nagar, Gwalior Birla Nagar, So, Gird, Through National E Gwalior, Mp Assessment Centre, Delhi (Appellant) (Respondent) Pan: Aacfc0885F Assessee By : Shri Ramakant Gupta, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/03/2026 Date Of Pronouncement 02/04/2026

For Appellant: Shri Ramakant Gupta, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 143(3)

…w is very well settled that the interest payment made on delayed payment of TDS is not an allowable deduction. Reliance in this regard is placed on the decision of Hon’ble Madras High Court in the case of CIT vs Chennai Properties & Investment Ltd reported in 239 ITR 435 (Mad) wherein it was held that interest paid on delayed payment of tax is not an allowable deduction as interest partakes the character of the principal portion i.e. tax and that since tax is not an allowable deduction, the interest thereon would also not be allowed as deduction. Drawing the same analogy, we hold that the interest paid on delayed…

Sri Rama Agri Genetics (India) Private Limited, Kurnool vs. DCIT., Circle-1, Kurnool

In the result, the appeal of the assessee is partly allowed

ITA 1179/HYD/2025[2015-16]Status: DisposedITAT Hyderabad21 Jan 2026AY 2015-16

Section 142(1)Section 143(3)Section 201Section 263Section 36(1)(iii)Section 36(1)(va)Section 41(1)Section 68

…egory of revenue expenditure and should be allowed as deduction under Section 37(1) of the Act. The A.O. disallowed the interest paid on TDS by following the decision of Hon'ble Madras High Court in the case of CIT Vs. Chennai Properties and Investments Ltd., 239 ITR 435 (Mad), where it has been held that, interest under Section 201(1A) paid by the assessee does not assume the character of business expenditure and also cannot be regarded as compensatory payment. On appeal, the Ld. CIT(A) confirmed the additions made by the A.O. 16. Aggrieved by the order of Ld. CIT(A), the assessee is now in appeal before the Tri…

Sheth Realtors, Mumbai vs. ACIT-CC-7(1), Mumbai

In the result, the appeal by the assessee is partly allowed for statistical purposes

ITA 5947/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Arun Khodpiashri Sandeep Singh Karhailsheth Realtors Vasant Oasis, Site Office, Upper Basement, Cts No.345A 1 To 3, 345A 5 To 6, Makwana Road, Marol, Andheri (East), ............... Appellant Mumbai – 400059 Pan: Aavfa3975F

For Appellant: Dr. K ShivramFor Respondent: Shri Vivek Perampurna, CIT-DR

Section 133(6)Section 139(1)Section 2(24)(x)Section 250

…the assessee was an expenditure incidental to business and allowable as a deduction from the profits and gains of the business, came up for consideration before the Hon’ble Madras High Court in CIT vs. Chennai Properties & Investment Ltd., reported in [1999] 239 ITR 435 (Madras). While answering the issue in negative and in favour of the Revenue, the Hon’ble Madras High Court, after considering the decision of the Hon’ble Supreme Court in the case of Bharat Commerce & Industries Ltd. vs. CIT, reported in [1998] 230 ITR 733 (SC), observed as follows: - “14. As already noticed, the payment of interest which takes…

ACIT., Circle-6(1), Hyderabad vs. Vk Warehousing Enterprises, Hyderabad

In the result, both the appeals filed by the assessee firm and

ITA 881/HYD/2025[2017-18]Status: DisposedITAT Hyderabad07 Jan 2026AY 2017-18

For Appellant: Shri Rajesh Vaishnav, C.AFor Respondent: Shri P. Dhivahar, CIT-DR

Section 143(2)Section 144Section 234BSection 271(1)(b)Section 40Section 68Section 69Section 69CSection 801B

…. 1,37,887/- paid on delayed remittance of TDS, we find no infirmity in the order of the CIT(A). The issue is squarely covered against the assessee firm by the judgment of the Hon'ble High Court of Madras in CIT v. Chennai Properties & Investments Ltd. (1999) 239 ITR 435 (Madras). Accordingly, we uphold the aforesaid disallowance. 13. As regards the disallowance of Rs. 32,89,736/- under Section 40(a)(ia), we note that although the assessee firm did not substantiate its claim either before the AO or before the CIT(A), it has contended before us that tax was duly deducted and deposited within the prescribed time. I…

Vk Warehousing Enterprises, Hyderabad vs. DCIT., Circle-6(1), Hyderabad

In the result, both the appeals filed by the assessee firm and the revenue are partly allowed for statistical purposes, in terms of our observations recorded hereinabove

ITA 737/HYD/2025[2017-18]Status: DisposedITAT Hyderabad07 Jan 2026AY 2017-18

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.737/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) M/S. V K Warehousing Enterprises, Dy. Commissioner Of Income Tax, Vs. Circle 6(1), Hyderabad. Hyderabad. Pan : Aakfv3288R (Appellant) (Respondent) आ.अपी.सं /Ita No.881/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) Dy. Commissioner Of Income Tax, M/S. V K Warehousing Enterprises, Circle 6(1), Hyderabad. Vs. Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rajesh Vaishnav, C.A. राज" व "ारा/Revenue By: Shri P. Dhivahar, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026

For Appellant: Shri Rajesh Vaishnav, C.AFor Respondent: Shri P. Dhivahar, CIT-DR

Section 143(2)Section 144Section 234BSection 271(1)(b)Section 40Section 69Section 69CSection 801B

…emittance of TDS, we find no infirmity in the order of the CIT(A). The issue is squarely covered against the ITA Nos.737 & 881/Hyd/2025 8 assessee firm by the judgment of the Hon’ble High Court of Madras in CIT v. Chennai Properties & Investments Ltd. (1999) 239 ITR 435 (Madras). Accordingly, we uphold the aforesaid disallowance. 13. As regards the disallowance of Rs. 32,89,736/- under Section 40(a)(ia), we note that although the assessee firm did not substantiate its claim either before the AO or before the CIT(A), it has contended before us that tax was duly deducted and deposited within the prescribed time.…

Nippon Koei Co. Ltd., Begumpet vs. ADIT (International Taxation)- 2, Hyderabad

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 670/HYD/2023[2021-22]Status: DisposedITAT Hyderabad20 Nov 2025AY 2021-22

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.670/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2021-22) M/S Nippon Koei Co. Ltd Vs. Adit (International Hyderabad Taxation)-2, Pan:Aabcn8434F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gsv Prasad, Anand Swaroop & S K Mohanty, Cas राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 27/10/2025 घोषणा की तारीख/Pronouncement: 21/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri GSV Prasad, Anand Swaroop and S K Mohanty, CAsFor Respondent: : Smt. U. Mini Chandran, CIT(DR)

Section 143(2)Section 143(3)Section 144CSection 144C(1)Section 144C(13)Section 144C(5)Section 201Section 37(1)Section 40Section 44D

…decision of this Tribunal in the case of Trinity Infraventures Ltd. vs. ACIT (supra), as relied upon by the Ld. AR. On perusal of the same, we found that the decision of the Hon’ble Madras High Court in the case of CIT vs. Chennai Properties & Investment Ltd. 239 ITR 435 was not considered by the Tribunal while passing that order. We have gone through the relevant Page 4 of 20 ITA No 670 of 2023 Nippon Koei Co Ltd portion of the order of the Hon’ble Madras High Court in the case of CIT vs. Chennai Properties & Investment Ltd (Supra) which is to the following effect: 8. On perusal of the above, we find that in…

Bank of Baroda, Mumbai vs. Assistant Commissioner of Income Tax, Circle 2(1)(1), Mumbai

The appeals of the appellant are partly allowed for statistical purposes

ITA 2392/MUM/2025[2020-21]Status: DisposedITAT Mumbai26 Aug 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Omkareshwar Chidara (Am)

For Appellant: Shri Leyaqat Ali AafaquiFor Respondent: Shri C. Naresh

Section 143(3)Section 90(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL Mumbai “B” Bench, Mumbai. Before Shri Narender Kumar Choudhry (JM) & Shri Omkareshwar Chidara (AM) ITA No. 1243/MUM/2025 (Assessment Year : 2018-19) ITA No. 2392/MUM/2025 (Assessment Year : 2020-21) Bank of Baroda ACIT-2(1)(1) Baroda Corporate Centre Room No. 561 2nd Floor, C-26, G Block Vs. 5th Floor Bandra Kurla Complex Aayakar Bhavan Bandra East M.K. Road Mumbai-400 051. Mumbai-40 0020. PAN : AAACB1534F Appellant Respondent : Shri C. Naresh Assessee by : Shri Leyaqat Ali Aafaqui Revenue by : 09/07/2025 Date of Hearing Date of pronouncement : 26/08/2025 O R D E R Per O…

Bank of Baroda, Mumbai vs. Assistant Commissioner of Income Tax, Circle 2(1)(1), Mumbai

The appeals of the appellant are partly allowed for statistical purposes

ITA 1243/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Aug 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Omkareshwar Chidara (Am)

For Appellant: Shri Leyaqat Ali AafaquiFor Respondent: Shri C. Naresh

Section 143(3)Section 90(3)

Bank of Baroda, Mumbai vs. Assistant Commissioner of Income Tax, Circle 2(1)(1), Mumbai

The appeals of the appellant are partly allowed for statistical purposes

ITA 1241/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Aug 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Omkareshwar Chidara (Am)

For Appellant: Shri Leyaqat Ali AafaquiFor Respondent: Shri C. Naresh

Section 143(3)Section 90(3)

Asianet Satellite Communications Limited, Thiruvananthapuram vs. Assistant Commissioner of Income Tax, Thiruvananthapuram

In the result, appeal filed by the assessee stands allowed

ITA 473/COCH/2025[2016-17]Status: DisposedITAT Cochin08 Aug 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K, Jm

For Appellant: Shri Raghunathan S, AdvocateFor Respondent: Smt. Leena Lal, Sr. DR

Section 143(3)Section 250Section 263Section 37(1)

…acter of business expenditure placing reliance on the decision of Hon'ble Calcutta High Court in the case of Martin & Harris (P.) Ltd. (1993) 73 taxman 555 (Cal.) and Hon'ble Madras High Court in the case of CIT vs. Chennai Properties & Investment Ltd. (1999) 239 ITR 435 (Mad.). Asianet Satellite Communications Ltd. 4. Being aggrieved, assessee filed an appeal before the learned CIT(A), who vide confirmed the action of the AO. 5. Being aggrieved by the order of learned CIT(A), the assessee is in appeal before this Tribunal in the present appeal. 6. It is contended that payment of interest under the provisions of…

DCIT-C-6(2), Mumbai vs. Samira Habitats India Limited, Mumbai

In the result, the cross-objection by the assessee for the assessment year 2012-13 is dismissed

ITA 5714/MUM/2024[2012-13]Status: DisposedITAT Mumbai09 May 2025AY 2012-13

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailita No.5714/Mum/2024 Assessment Year : 2011-12 Assessment Year : 2012-13 Assessment Year : 2009-10

For Appellant: Shri Rakesh JoshiFor Respondent: Dr. Kishor Dhule, CIT-DR

Section 132(4)Section 250

…by the assessee was an expenditure incidental to business and allowed as a deduction from the profits and gains of the business, came up for consideration before the Hon’ble Madras High Court in CIT vs. Chennai Properties & Investment Ltd., reported in [1999] 239 ITR 435 (Madras). While answering the issue in negative and in favour of the Revenue, the Hon’ble Madras High Court, after considering the decision of the Hon’ble Supreme Court in the case of Bharat Commerce & Industries Ltd. v/s CIT, reported in [1998] 230 ITR 733 (SC), observed as follows: - “14. As already noticed, the payment of interest which takes…

DCIT-C-6(2), Mumbai vs. Samira Habitats, Mumbai

In the result, the appeal by the Revenue for the

ITA 5710/MUM/2024[2009-10]Status: DisposedITAT Mumbai09 May 2025AY 2009-10

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Rakesh JoshiFor Respondent: Dr. Kishor Dhule, CIT-DR

Section 132(4)Section 250

…by the assessee was an expenditure incidental to business and allowed as a deduction from the profits and gains of the business, came up for consideration before the Hon'ble Madras High Court in CIT vs. Chennai Properties & Investment Ltd., reported in [1999] 239 ITR 435 (Madras). While answering the issue in negative and in favour of the Revenue, the Hon'ble Madras High Court, after considering the decision of the Hon'ble Supreme Court in the case of Bharat Commerce & Industries Ltd. v/s CIT, reported in [1998] 230 ITR 733 (SC), observed as follows: - "14. As already noticed, the payment of interest which takes…

DCIT-C-6(2), Mumbai vs. Samira Habitats India Limited, Mumbai

In the result, the appeal by the Revenue for the

ITA 5709/MUM/2024[2011-12]Status: DisposedITAT Mumbai09 May 2025AY 2011-12

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Rakesh JoshiFor Respondent: Dr. Kishor Dhule, CIT-DR

Section 132(4)Section 250

…by the assessee was an expenditure incidental to business and allowed as a deduction from the profits and gains of the business, came up for consideration before the Hon'ble Madras High Court in CIT vs. Chennai Properties & Investment Ltd., reported in [1999] 239 ITR 435 (Madras). While answering the issue in negative and in favour of the Revenue, the Hon'ble Madras High Court, after considering the decision of the Hon'ble Supreme Court in the case of Bharat Commerce & Industries Ltd. v/s CIT, reported in [1998] 230 ITR 733 (SC), observed as follows: - “14. As already noticed, the payment of interest which takes…

M/S. R R Kapoor Company, Ahmednagar vs. The Income-Tax Officer, Ward-2, Ahmednagar

In the result, the appeal of the assessee is partly allowed

ITA 2645/PUN/2024[2014-15]Status: DisposedITAT Pune02 Apr 2025AY 2014-15

Bench: Dr.Manish Borad

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Aviyogi Ambadkar

Section 143(2)Section 143(3)Section 36(1)(va)Section 37

…n TDS. In my considered view the interest paid on late payment of TDS u/s.201/201(1A) is not an allowable expenditure and for this I find support from the judgment of Hon’ble Madras High Court in the case of CIT Vs. Chennai Properties & Investment Ltd. (1999) 239 ITR 435. Ld. AR failed to controvert the binding precedent. I therefore fail to find any merit in this ground raised by the assessee. Accordingly, finding of ld.CIT(A) is affirmed and ground No.4 raised by the assessee is dismissed. 11. Ground No.5 being general in nature needs no adjudication. 12. In the result, the appeal of the assessee is partly al…

Spb Projects and Consultancy Ltd., Chennai vs. ITO Corp. Ward 6(1), Chennai

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 3303/CHNY/2024[2022-23]Status: DisposedITAT Chennai14 Mar 2025AY 2022-23

Bench: Shri George George K & Shri Jagadish

For Appellant: Shri N.R.Suresh, F.C.AFor Respondent: Ms. Anitha, Addl.CIT

Section 143(1)Section 201Section 250Section 36(1)(va)Section 37Section 37(1)Section 43B

…”. 10. The issue of interest paid u/s.201(1A) of Act, whether it is an allowable deduction is covered against the assessee by the judgement of Hon’ble Jurisdictional High Court in the case of CIT Vs. Chennai Properties & Investment Limited reported in (1999) 239 ITR 435 (Mad) dated 20.04.1998. The Hon’ble High Court had held that “when assessee failed to deduct tax at source and remit the same to State and assessee having paid interest u/s.201(1A) of the Act for delayed period, it cannot be claimed as business deduction”. It was further held by the Hon’ble Court that “interest paid takes colour from the nature o…

Vazhraa Nirmaan Private Limited, Hyderabad vs. I.T.O. Circle-8(1), Hyderabad

In the result, the appeal of the assessee is partly allowed

ITA 977/HYD/2024[2018-2019]Status: DisposedITAT Hyderabad24 Feb 2025AY 2018-2019

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri V. Siva Kumar, AdvocateFor Respondent: Dr. Sachin Kumar, SR-DR

Section 37(1)

…their submission, the Ld. DR relied on the decision of Hon'ble Supreme Court in the case of Bharat Commerce & Industries Limited Vs. CIT 230 ITR 733 (SC) and decision of Hon'ble Madras High Court in the case of CIT Vs. Chennai Properties & Investment Limited 239 ITR 435 (Mad). 5. We have heard the rival contentions and also gone through the record in the light of the submissions made by either side. As far as the addition of Rs.66,710/-, on account of interest on delay payment of TDS is concerned, since the assessee has not pressed this issue, the same is dismissed as not pressed. 5.1 As far as the reliance of L…

Upakar Infra Projects Private Limited, Hyderabad vs. ACIT, Cent Cir-2(4), Hyderabad

In the result, the appeal of the revenue is dismissed

ITA 379/HYD/2023[2018-19]Status: DisposedITAT Hyderabad07 Jan 2025AY 2018-19

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Shri Madan Mohan Meena

Section 132Section 139Section 143(2)Section 153CSection 201Section 36(1)(iii)

…for the purpose of business and further it is a payment, which is in the form of tax so it is not an allowable expenditure. The ITAT dismissed the appeal of the assessee. 13. The Hon'ble Madras High Court in CIT Vs. Chennai Properties & Investment Ltd. (1999) 239 ITR 435 (Mad.) has held that interest under section 201(1A) paid by the assessee does not assume the character of business expenditure and also cannot be regarded as compensatory payment. ITA Nos.377 to 380/Hyd/2023, 5 383/Hyd/2023 & 384/Hyd/2023 14. This decision of Hon'ble Madras High Court has also been followed by various benches of ITAT, specifica…

Upakar Infra Projects Private Limited, Hyderabad vs. ACIT, Cent Cir-2(4), Hyderabad

In the result, the appeal of the revenue is dismissed

ITA 378/HYD/2023[2012-13]Status: DisposedITAT Hyderabad07 Jan 2025AY 2012-13

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Shri Madan Mohan Meena

Section 132Section 139Section 143(2)Section 153CSection 201Section 36(1)(iii)

Eastern Cargo Carriers (India) Private Limited, Mumbai, Maharashtra, India vs. The Assessment Unit, Income Tax Department

In the result, the appeal of the In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 4610/MUM/2023[2021-2022]Status: DisposedITAT Mumbai20 Dec 2024AY 2021-2022

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2021-22 M/S Eastern Cargo Carriers (India) The Assessment Unit, Income Tax Pvt. Ltd., Department, Vs. Unit No. 26, Adarsh Ind. Estates, Aaykar Bhavan, M.K. Road, Sahar Road, Andheri East, Mumbai-400020. Mumbai-400099. Pan No. Aaace 1520 E Appellant Respondent

For Appellant: Mr. Niraj Sheth a/wFor Respondent: Mr. Hemanshu Joshi, Sr. DR

Section 40A(2)(a)

…as already been considered by Hon'ble Madras High Court in has already been considered by Hon'ble Madras High Court in CIT Vs. has already been considered by Hon'ble Madras High Court in Chennai Properties & Investment Ltd. Properties & Investment Ltd. (1999) 239 ITR 435 (Mad.) (1999) 239 ITR 435 (Mad.) wherein it has been held that interest under Section 201(1A) wherein it has been held that interest under Section 201(1A) of the Act paid by the assessee does not assume the character of business Act paid by the assessee does not assume the character of business Act paid by the assessee does not assume the charact…

ACIT 14 (1)(2), Mumbai vs. Shriram Chits Maharastra Limited, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 66/MUM/2024[2017-18]Status: DisposedITAT Mumbai03 Jun 2024AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18

For Appellant: Mr. Raghav MenonFor Respondent: Mr. Ashok Kumar Ambastha, Sr. DR

Section 37(1)

…l of the assessee. 13. The Hon’ble Madras High Court in CIT Vs. Chennai Properties 13. The Hon’ble Madras High Court in CIT Vs. Chennai Properties 13. The Hon’ble Madras High Court in CIT Vs. Chennai Properties & Investment Ltd. (1999 & Investment Ltd. (1999) 239 ITR 435 (Mad.) has held that interest ) 239 ITR 435 (Mad.) has held that interest under section 201(1A) paid by the assessee does not assume the under section 201(1A) paid by the assessee does not assume the under section 201(1A) paid by the assessee does not assume the character of business expenditure and also cannot be regarded as character of busines…