“Section 36(1)”

Section References (mined)Section 36Section 36(1)3,872 judgments

The decision most relied on for Section 36(1) is CIT v. Reliance Utilities & Power Ltd. (313 ITR 340), cited in 2,118 judgments on BharatTax.

Leading authorities on Section 36(1)

CIT v. Reliance Utilities & Power Ltd.

313 ITR 340 · 2009 · High Court

2,118

citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

CIT v. AIMIL Ltd.

321 ITR 508 · 2010 · High Court

1,629

citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

S.A. Builders Ltd. v. CIT

288 ITR 1 · 2007 · Supreme Court

1,484

citing judgments

Interest paid on borrowed funds cannot be disallowed merely because the assessee made interest-free advances, provided those advances were made for business purposes and commercial expediency. The Revenue cannot dictate a businessman's commercial decisions, but the assessee bears the onus to prove the business expediency.

Checkmate Services Pvt. Ltd. v. CIT

143 Taxmann.com 178 · 2022 · Supreme Court

1,392

citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Alom Extrusions Ltd.

319 ITR 306 · 2009 · Supreme Court

1,344

citing judgments

A proviso inserted into a section to remedy unintended consequences, make the section workable, or supply an obvious omission must be read retrospectively in operation to give effect to the section as a whole.

CIT v. HDFC Bank Ltd.

366 ITR 505 · 2014 · High Court

1,261

citing judgments

When an assessee possesses interest-free funds sufficient to cover investments yielding tax-free income, it is presumed that such investments were made from these interest-free funds, precluding disallowance of interest expenditure under Section 14A.

CIT v. Gujarat State Road Transport Corporation

366 ITR 170 · 2014 · High Court

1,158

citing judgments

Employees' contributions to welfare funds, such as provident fund, are not allowable as a deduction under section 36(1)(va) if deposited beyond the due date prescribed under the respective welfare statutes, even by a single day. Such delayed deposits are not cured even if made before the income-tax return filing due date.

TRF Ltd. v. CIT

323 ITR 397 · 2010 · Supreme Court

714

citing judgments

For claiming deduction for bad debts under section 36(1)(vii) of the Income Tax Act, it is sufficient for the assessee to write off the debt as irrecoverable in its accounts, and it is not necessary to prove that the debt has actually become irrecoverable.

Judgments citing Section 36(1)

Capacite Infraprojects Limited, Mumbai vs. ACIT/DCIT Central Circle 1(2) Mumbai, Mumbai

The appeal of the assessee are allowed in above terms

ITA 6309/MUM/2024[2018-19]Status: DisposedITAT Mumbai10 Sept 2025AY 2018-19

Bench: Shri. Om Prakash Kant & Shri. Raj Kumar Chauhan

Section 115JSection 132Section 153ASection 23(1)Section 250Section 270ASection 36(1)(VA)Section 9

wherein it has been concluded that there is a marked distinction between the nature and character of the employer's contribution under section 36(1)(iv) of the IT Act and the employee's contribution under section 36(1)(va) of the ITA No. 6315 & 6309/Mum/2024 CapaciteInfraprojects Limited ... case of section 36(1) (iv) of the IT Act, the employer's liability is to be paid out of its income whereas the second is deemed to be an income, by definition, since it is the deduction from the employee's income and held in trust by the employer

Pradeep Sharma, Jaipur vs. Income Tax Officer, Jaipur

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

ITA 1522/JPR/2024[2017-18]Status: DisposedITAT Jaipur09 Sept 2025AY 2017-18

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR

Section 143(3)Section 36(1)(vii)

offered and outstanding amount not recoverable, is written off in the books of accounts. Appellant prays that both the conditions laid down in section 36(1)(vii) are satisfied and bad debts have been rightly claimed by assessee, (being clearly covered by provisions of the Act as well as allowable ... failed to furnish documentary evidence in support of his claim. He also noted that the assessee failed to prove that the conditions of section 36(1)(vii) had been fulfilled in respect of these expenses written off by it. Hence, the said claim of the assessee was not considered

Kothari Agritech Pvt. Ltd, Solapur vs. The DCIT, Circle-1, Solapur

In the result, the both appeals of the assessee in ITA Nos

ITA 2455/PUN/2024[2018-2019]Status: DisposedITAT Pune09 Sept 2025AY 2018-2019

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Nikhil TiwariFor Respondent: Shri Ramnath P Murkunde

Section 143Section 143(1)Section 143(1)(a)Section 143(3)Section 14ASection 154Section 80Section 801ASection 80ISection 80J

provident fund, employee state insurance corporation and labour welfare fund under clause 20(b). The CPC vide its notice proposed an adjustment under section 36(1)(va) of the Act in relation to aforesaid contribution amounting to Rs. 13,06,741. The Appellant filed response letter dated 18/03/21 to Jurisdiction

Kothari Agritech Private Limited, Solapur vs. DCIT Circle-1, Solapur

In the result, the both appeals of the assessee in ITA Nos

ITA 2392/PUN/2024[2018-19]Status: DisposedITAT Pune09 Sept 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Nikhil TiwariFor Respondent: Shri Ramnath P Murkunde

Section 143Section 143(1)Section 143(1)(a)Section 143(3)Section 14ASection 154Section 80Section 801ASection 80ISection 80J

M/S. City Union Bank, Kumbakonam vs. PCIT, Madurai

In the result, both the appeals for A

ITA 1479/CHNY/2025[2021-22]Status: DisposedITAT Chennai09 Sept 2025AY 2021-22

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 1478 & 1479/Chny/2025 धनिाारण वर्ा / Assessment Year: 2020-21 & 2021-22 M/S. City Union Bank, Pcit No. 148-149, T.S.R Big Street, Vs. Madurai – 1. Kumbakonam – 621 001. Tamil Nadu. [Pan: Aaacc-1287-E] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Mr. S. Ananthan, Ca & Ms. R. Lalitha, Ca प्रत्यथी की ओर से/Respondent By : Ms. E. Pavuna Sundari, Cit. सुनवाई की तारीख/Date Of Hearing : 28.08.2025 घोर्णा की तारीख/Date Of Pronouncement : 09.09.2025

For Appellant: Mr. S. Ananthan, CA and Ms. R. Lalitha, CAFor Respondent: Ms. E. Pavuna Sundari, CIT

Section 17(2)Section 263Section 36(1)(vii)Section 36(1)(viia)

verified by the learned Assessing Officer. :-3-: ITA. Nos:1478 & 1479/Chny/2025 6. The Learned Principal Commissioner erred in holding that the claim under section 36(1)(viia) is allowable on incremental advances only and not on outstanding advances. 6.1. Learned Principal Commissioner failed to appreciate the fact that the issue

M/S. City Union Bank, Kumbakonam vs. PCIT, Madurai

In the result, both the appeals for A

ITA 1478/CHNY/2025[2020-21]Status: DisposedITAT Chennai09 Sept 2025AY 2020-21

For Appellant: Mr. S. Ananthan, CA and Ms. R. Lalitha, CAFor Respondent: Ms. E. Pavuna Sundari, CIT

Section 17(2)Section 263Section 36(1)(vii)Section 36(1)(viia)

Concept Motors (India) Pvt Ltd, Delhi vs. Assessing Officer, Circle-4(2), Delhi

ITA 373/DEL/2025[2018-19]Status: DisposedITAT Delhi09 Sept 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year: 2018-19

Section 139(1)Section 143(1)Section 143(3)Section 36(1)(va)

taxmann.com 178 (SC), wherein their lordships have settled the law that the compliance to section 36(1)(va) ought to be as per the “due” date of the corresponding statute than that of u/s 139(1) of the Act. The Hon’ble Bombay High Court in Rohan Korgaonkar v. DCIT

M/S.Joy Alukkas India P. Ltd, Cochin vs. The ACIT, Cochin

In the result, the appeal filed by the Assessee stands partly allowed for statistical purposes

ITA 38/COCH/2017[2012-13]Status: DisposedITAT Cochin08 Sept 2025AY 2012-13

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 36(1)(iii)Section 36(1)(viii)Section 92C

working capital loans availed from banks as incurred for acquisition of assets and disallowing the same under proviso to section 36(1)(iii) on notional basis. The improvements to leasehold properties was considered as a revenue expenditure and hence the proviso to section 36(1) (iii) was not applicable ... 643/Coch/2017 M/s. Joyalukkas India Pvt. Ltd. 12. The ground of appeal No.9 challenges the disallowance of interest under the proviso to section 36(1) of the Act of Rs. 1,39,04,056/-. It is submitted before us that the issue stands covered in favourof the Assessee by this Tribunal

M/S.Joy Alukkas India P. Ltd, Trichur vs. The ACIT, Ernakulam

In the result, the appeal filed by the Assessee stands partly allowed for statistical purposes

ITA 119/COCH/2016[2011-12]Status: DisposedITAT Cochin08 Sept 2025AY 2011-12

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 36(1)(iii)Section 36(1)(viii)Section 92C

DCIT, C-V, Ludhiana vs. M/S Hero Cycles Ltd., Ludhiana

In the result, appeal of the Department is dismissed and the appeal of the assessee is allowed

ITA 588/CHANDI/2018[2012-13]Status: DisposedITAT Chandigarh08 Sept 2025AY 2012-13

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 588/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 The DCIT C-V, Ludhiana बनाम M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 473/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana बनाम The ACIT C-V, Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P

For Appellant: Shri Ashwani Kumar, Shri Ashish Aggarwal &For Respondent: Shri Manav Bansal, CIT, DR

Section 10(38)Section 143(1)Section 14ASection 36(1)(iii)

dismissed. 18. The next issue vide ground no.(iii) relates to the deletion of disallowances of interest made by the A.O. under section 36(1) (iii) of the Act. 19. The facts related to this issue in brief are that the A.O. made various disallowance of interest ... under section 36(1) (iii) of the Act by observing in para 6.1 of the assessment order dt. 03/03/2015 which read as under: "During the course of the Assessment Proceedings the details regarding the Debtors as standing in the Balance Sheet of the Assessee as on 31.3.2012 were called

M/S Hero Cycles Ltd., Ludhiana vs. ACIT, C-V, Ludhiana

ITA 473/CHANDI/2018[2012-13]Status: DisposedITAT Chandigarh08 Sept 2025AY 2012-13

For Respondent: Shri Ashwani Kumar, Shri Ashish Aggarwal &

Section 10(38)Section 143(1)Section 14ASection 36(1)(iii)

Lowes Services India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle 4(1)(1), Bangalore

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

ITA 1734/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore08 Sept 2025

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Shri Chavali Narayan, ARFor Respondent: Dr. Divya K J, CIT(DR)(ITAT), Bengaluru

Section 143(1)Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 36(1)(va)Section 80G

erred in law and in the facts of the case by considering the disallowance of INR 1,32,825/- under Section 36(1)(va) of the Act twice in the assessment order, when the same was already included in the enhanced income as per the intimation order under Section

Dy. Commissioner of Income-Tax, Central Circle-1, Visakhpatnam vs. M/S. Sardar Projects Pvt. Ltd, Visakhapatnam

In the result, appeal of the revenue is dismissed

ITA 357/VIZ/2025[2021-22]Status: DisposedITAT Visakhapatnam04 Sept 2025AY 2021-22

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita No. 357/Viz/2025 (A.Y. 2021-22) Dcit – Central Circle – 1 V. M/S. Sardar Projects Pvt Ltd., 5Th Floor, Direct Taxes Building 7-5-64, Plot No. 48 Mvp Colony, Visakhapatnam – 530017 Pandurangarpuram Andhra Pradesh Visakhapatnam – 530003 Andhra Pradesh [Pan:Aakcs3773K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 132Section 142(1)Section 143(2)Section 143(3)Section 36(1)(iii)Section 69A

additions with respect to short admission of sales amounting to Rs.3,00,000/-. Further he also made addition of Rs.4,41,082/- under section 36(1)(iii) of the Act considering notional interest @12% on the advance given to Shri J.V. Giri. 3. Aggrieved by the additions made

Azure Knowledge Corporation Private Limited, Ahmedabad vs. The Dy.CIT, Circle-1(1)(1), Ahmedabad

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

ITA 2012/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad04 Sept 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2017-18

Section 143(3)Section 250Section 36(1)(iii)Section 36(1)(va)

Assessing Officer had made additions on account of disallowance of subsidy on intangible asset, disallowance of depreciation on intangible asset, disallowance under Section 36(1)(iii) of the Act and disallowance under Section 36(1)(va) of the Act. 3. Aggrieved with the order of the Assessing Officer, the assessee ... ground taken by the assessee is allowed. 12. The next ground pertains to disallowance of interest expense of Rs.35,76,692/- under Section 36(1)(iii) of the Act. The Ld. AR explained that the assessee had given advance of Rs.2,98,05,733/- to Bennet Coleman & Co. Limited (BCCL

Satya Pratap Singh Kunwar, Uttar Pradesh vs. Jurisdictional Assessing Officer, Ward 2(3), Faridabad, Haryana

In the result, the appeal filed by the assessee is partly allowed

ITA 984/DEL/2025[2020-2021]Status: DisposedITAT Delhi03 Sept 2025AY 2020-2021

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR KUMAR (Judicial Member)

For Appellant: Shri Hemant Jain, AdvocateFor Respondent: Shri Dheeraj Kumar Jain, Sr. DR

Section 143(1)Section 143(1)(a)Section 154Section 2(24)(x)

considered the rival submissions and perused the material available on record. The disallowance of employees’ contribution to PF/ESIC for breach of condition under Section 36(1)(va) is in controversy. 9.1 We notice at the outset that an opportunity was given via electronic platform of the deptt. For the proposed ... merit in such plea that the belated deposit of employees contributions to PF/ESIC governed under Section 36(1)(va) is also simultaneously amenable to deduction under Section 37(1) of the Act. In terms of the provision, Section 37(1) permits deduction of expenditure which is not in the nature

Ponnusamy Raja, Vakkil New Street, Madurai vs. Income Tax Officer, Non-Corporate Ward 1(7), Madurai, Income Tax Office, Cr Building

In the result, the appeal filed by the assessee is allowed

ITA 1677/CHNY/2025[2018-2019]Status: DisposedITAT Chennai02 Sept 2025AY 2018-2019

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1677/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Ponnusamy Raja, Vs. The Income Tax Officer, No. 176-A, 3Rd Floor, Vakkil New Street, Non Corporate Ward 1(7), Simmakal, Madurai 625 001. Madurai. [Pan:Agepr6307F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Vasudevan, Advocate ""थ" की ओर से/Respondent By : Shri N. Rajakumar, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 26.08.2025 घोषणा की तारीख /Date Of Pronouncement : 02.09.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 04.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2018-19. 2. We Find That This Appeal Is Filed With A Delay Of 9 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We Find The Reasons Stated By The Assessee Are Bonafide, Which Really

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Shri N. Rajakumar, Addl. CIT

Section 36(1)(ii)Section 44A

audit report, the Assessing Officer noted mismatch in amount paid to 3 I.T.A. No.1677/Chny/25 employees as bonus or commission under section 36(1)(ii) of the Act. The assessee submitted before the Assessing Officer that the bonus amount of ₹.2,26,000/- was wrongly reported in tax audit report

Navaneetha Enterprises, Bengaluru vs. Income Tax Officer, Ward-2(2)(2), Bengaluru

ITA 661/BANG/2025[2019-20]Status: DisposedITAT Bangalore02 Sept 2025AY 2019-20

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri Ravikiran, CAFor Respondent: Shri Subramanian .S, JCIT-DR

Section 36(1)(va)

wages and EPF liabilities electronically and file Electronic Challan cum Return (ECR); the remittances are also being deposited through Internet Banking. 2. 4. Section 36(1)(va) of the Income Tax Act, 1961 requires your appellant to remit the contributions before the due date. Explanation 1 to the said section

M/S.Apollo Tyres Ltd, Cochin vs. The Principal Commissioner of Incometax, Cochin

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

ITA 609/COCH/2017[2013-14]Status: DisposedITAT Cochin01 Sept 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2013-14 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Dcit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 01.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 115JSection 143(3)Section 32Section 32(1)(iia)Section 35Section 43(1)Section 92C

narrative on how this aspect of the matter is examined by the Courts, we refer to the following decisions: Core Health Care Ltd: Section 36(1)(iii) of the Income-tax Act, 1961, has to be read on its own terms: it is a code by itself. It makes ... carried on by the assessee in the year of account. Unlike Section 37 which expressly excludes an expense of a capital nature, section 36(1)(iii) emphasises the user of the capital and not the user of the asset which comes into existence as a result of the borrowed capital

Mr. Ashish Arora, Ludhiana vs. DCIT, Ludhiana

In the result, appeal of the Assessee is dismissed

ITA 1152/CHANDI/2014[2010-11]Status: DisposedITAT Chandigarh01 Sept 2025AY 2010-11

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1152/Chd/2014 "नधा"रण वष" / Assessment Year : 2010-11 Mr. Ashish Arora, The Dcit B-2, Kitchlu Nagar, बनाम Circle Iii, Ludhiana Rishi Nagar, Vs. Ludhiana "थायी लेखा सं./ Pan No: Adkpa1111B अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Sh. Manav Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 07.07.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 01.09.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 19.02.2014 Passed By The Ld. Commissioner Of Income Tax (Appeals)-1. Ludhiana [Herein Referred To As Cit(A)]. The Captioned Appeal Was Dismissed For Non-Prosecution Vide Order Dated 26.7.2016 But Later On The Assessee Filed A Misc. Application Which 1152-Chd-2014 Ashish Arora, Ludhiana 2

For Appellant: Sh. Sudhir Sehgal, AdvocateFor Respondent: Sh. Manav Bansal, CIT DR

Section 133(6)Section 143(3)Section 36(1)(iii)Section 68

Income tax (Appeal-1) Ludhiana has erred in confirming the addition of Rs. 23,16,479/- on account of disallowance of interests under section 36(1)(iii) of the Income tax Act 1961 on the basis of observation made by the Assessing Officer while completing the assessment under section

Shri Jagdishbhai Gordhanbhai Doabariya, Rajkot vs. The Pr. CIT-1, Rajkot

In the result, appeal filed by the assessee, is allowed

ITA 142/RJT/2023[2018-19]Status: DisposedITAT Rajkot29 Aug 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.142/Rjt/2023 "नधा"रणवष"/ Assessment Year: 2018-19 Jagdishbhai Gordhanbhai Dobariya The Pr.Cit-1 बनाम “Ramdev”2, Jivnath Park,B/H. Panchvati Aayakar Bhavan, Race Hall,Panchvati Main Road,Nr.Gandhi Vs. Course Ring Road, School,Rajkot 360 001 Rajkot. Pan : Abrpd8654R (अपीलाथ"/Assessee) (""यथ"/Respondent) :

For Appellant: Shri Rajendra Singhal, ld.ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR

Section 143(3)Section 263Section 57

purpose of business are allowable. The ld.DR further stated that the case laws cited by the ld.Counsel for the assessee are pertaining to section 36(1) of the Act. The assessee has failed to prove the direct nexus between the loan given and loan taken. Therefore, the ld.DR