Madhav Prasad Jatia v. CIT

118 ITR 200Supreme Court of India1979#826 most cited

What is Madhav Prasad Jatia v. CIT authority for?

Interest on borrowed funds is deductible as a business expense under section 36(1)(iii) if incurred on grounds of commercial expediency, not for sentimental or personal reasons. The phrase 'for the purpose of business' is broader than 'for the purpose of earning income'.

125

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2010 to 2026.

Also referred to as

Madhav Prasad Jatia v. CIT · section 36(1)(iii) · business expenditure · commercial expediency · interest on borrowed funds · deduction · purpose of business · earning income · broader scope

Issues it is cited on

Judgments citing Madhav Prasad Jatia v. CIT

M/S. Sports Infratech Pvt. Ltd., New Delhi vs. DCIT, New Delhi

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

ITA 2045/DEL/2015[2011-12]Status: DisposedITAT Delhi13 Jun 2018AY 2011-12

Bench: Sh. N. K. Saini, Am & Sh. K. N. Chary, Jm Ita No. 2045/Del/2015 : Asstt. Year : 2011-12 M/S Sports Infratech Pvt. Ltd., Vs Dy. Commissioner Of Income Tax, 204, Okhla Industrial Estate, Central Circle-5, Phase-Iii, New Delhi-110020 New Delhi (Appellant) (Respondent) Pan No. Aabcj7255J Assessee By : Sh. Sanjay Jain, Ca & Sh. Rakesh Joshi, Ca Revenue By : Sh. S. S. Rana, Cit Dr Date Of Hearing : 05.04.2018 Date Of Pronouncement : 13.06.2018 Order Per N. K. Saini, Am: This Is An Appeal By The Assessee Against The Order Dated 30.01.2015 Of Ld. Cit(A)-24, New Delhi.

For Appellant: Sh. Sanjay Jain, CA &For Respondent: Sh. S. S. Rana, CIT DR
Section 133(6)Section 133ASection 142(1)Section 143(1)Section 143(2)Section 37

…are fulfilled, it is not possible and open to the Revenue to make a part disallowance, unless there is a positive finding recorded that a part of the amount borrowed was not used for the purposes of the business. As was observed in Madhav Prasad's case [1979] 118 ITR 200 (SC), the expression "for the purpose of business" appearing in section 36(1)(iii) and section 37(1) is wider in scope than the expression "for the purpose of making or earning income" used in section 57(iii). Therefore, the scope for allowing a deduction under section 36(1)(iii) is much wider than the one available under section 57(iii).” 41. Th…