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“disallowance of interest expenditure”

DisallowancesSection 36(1)(iii)Section 36(1)(iii)785 judgments

The decision most relied on for disallowance of interest expenditure is CIT v. Reliance Utilities & Power Ltd. (313 ITR 340), cited in 2,118 judgments on BharatTax.

Leading authorities on disallowance of interest expenditure

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. 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.

Godrej & Boyce Mfg. Co. Ltd. v. DCIT
328 ITR 81 · 2010 · High Court
1,183
citing judgments

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

South Indian Bank Ltd. v. CIT
438 ITR 1 · 2021 · Supreme Court
508
citing judgments

The mixed fund theory is affirmed, holding that no disallowance of interest expenditure under Section 14A can be made if the assessee possesses sufficient non-interest bearing funds, such as capital and reserves, to cover investments made in tax-free securities.

CIT v. Reliance Industries Ltd.
410 ITR 466 · 2019 · Supreme Court
501
citing judgments

When mixed funds are available, interest-free advances are presumed to be made from the assessee's own interest-free funds, preventing disallowance of interest expenditure under section 36(1)(iii). This principle also applies to section 14A disallowance, where interest expenditure is not disallowed if surplus funds are available and no direct nexus is established with borrowed funds for investments earning exempt income.

CIT v. Dalmia Cement (Bharat) Ltd.
254 ITR 377 · 2002 · High Court
417
citing judgments

When there is a nexus between an expenditure and the purpose of business, incurred on grounds of commercial expediency, the Revenue cannot question its reasonableness or assume the role of the businessman to compel profit maximization. This principle applies even if the business is not that of the assessee itself.

HDFC Bank Ltd. v. DCIT
383 ITR 529 · 2016 · High Court
408
citing judgments

Where an assessee has sufficient interest-free funds, investments yielding exempt income are presumed to be made out of such funds, precluding disallowance of related interest expenditure under section 14A.

Hero Cycles Pvt. Ltd. v. CIT
379 ITR 347 · 2015 · Supreme Court
361
citing judgments

The Revenue cannot substitute its judgment for that of a businessman regarding the necessity or reasonableness of an expenditure. If an expense is incurred wholly and exclusively for business purposes, it is deductible, and the Revenue cannot question its commercial expediency.

Judgments citing disallowance of interest expenditure

Meghalaya Energy Corporation Limited Gpf Trust, Lumjingshai, East Khasi Hills vs. ACIT-Circle, Shillong

In the result, the appeal filed by the assessee in ITA No

ITA 240/GTY/2025[2017-18]Status: DisposedITAT Guwahati13 Mar 2026AY 2017-18

Bench: Shriduvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

Section 14A

paid to the members of the GPF Trust was allowed by observing and holding as under:- “10. 2. Ground no. 2 relates to disallowance of interest expenditure at Rs.6,42,82,320/-. We notice that the assessee has claimed the expenditure towards accrued interest on G.P.F. subscriptions at Rs.6

Bhumi Polymers Private Limited, Rajkot vs. Income Tax Officer, Ward-1(1)(1), Rajkot

In the result, the appeal is dismissed

ITA 755/RJT/2025[2023-24]Status: DisposedITAT Rajkot12 Mar 2026AY 2023-24

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 755/Rjt/2025

Section 143(3)Section 270ASection 36(1)Section 37(1)Section 40Section 44A

disallowance of purchases of Rs.31,67,088/- u/s 37(1), disallowance of commission payments of Rs.1,02,58,562/- u/s 37(1), disallowance of interest expenditure of Rs.50,64,794/-u/s_36(1)(iii), disallowance of discount and miscellaneous expenses of Rs.16,48,578/- u/s 37(1) and disallowance of rent

Kaushal Hazarilal Agrawal, Vadodara vs. The Dy.CIT, Central Circle-1, Vadodara

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

ITA 7/AHD/2026[2017-18]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Karan Bakshi, AdvocateFor Respondent: Shri C Dharani Nath, Sr. DR
Section 142(1)Section 143(3)Section 144Section 148Section 263Section 57

therefore the order passed under section 144 read with section 263 was liable to be set aside. The assessee further challenged the disallowance of interest expenditure of ₹58,51,028/- claimed under section 57 of the Act and also objected to the initiation of penalty proceedings under sections 270A

Swd Industries, Mumbai vs. PCIT (Central), Mumbai-1, Mumbai

In the result, all the appeals filed by the assessee for the respective assessment years are allowed, and the impugned orders passed by the learned PCIT under section 263 of the Act are set aside

ITA 9012/MUM/2025[2020-2021]Status: DisposedITAT Mumbai12 Mar 2026AY 2020-2021

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 9007/Mum/2025 (Assessment Year: 2014-15) 2. Ita No. 9008/Mum/2025 (Assessment Year: 2015-16) 3. Ita No. 9009/Mum/2025 (Assessment Year: 2016-17) 4. Ita No. 9010/Mum/2025 (Assessment Year: 2017-18) 5. Ita No. 9011/Mum/2025 (Assessment Year: 2019-20) & 6. Ita No. 9012/Mum/2025 (Assessment Year: 2020-21) Swd Industries, Pcit (Central), 1402, South Tower 25, Mumbai-1, South Prabhadevi, Vs. R. No. 1001, 10Th Mumbai-400 025 Floor, Pratistha Bhavan, Old Cgo Annexe, Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aaofs8319L (Applicant) (Respondent) Assessee By Shri Salil Kapoor A/W Shri Sumit Lalchandani, Shri Shivam Yadav, Shri Shri Vinod Gupta, Ld. Ars Revenue By Shri Vivek Perampurna, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 143(3)Section 153CSection 153DSection 263

assessee and passed assessment orders determining the total income for the respective years. In some of the years, the Assessing Officer made disallowance of interest expenditure claimed by the assessee, while in other years the returned income was accepted. The assessments so framed were passed by the Assessing Officer after

Swd Industries, Mumbai vs. PCIT (Central), Mumbai-1, Mumbai

In the result, all the appeals filed by the assessee for the respective assessment years are allowed, and the impugned orders passed by the learned PCIT under section 263 of the Act are set aside

ITA 9011/MUM/2025[2019-2020]Status: DisposedITAT Mumbai12 Mar 2026AY 2019-2020

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 9007/Mum/2025 (Assessment Year: 2014-15) 2. Ita No. 9008/Mum/2025 (Assessment Year: 2015-16) 3. Ita No. 9009/Mum/2025 (Assessment Year: 2016-17) 4. Ita No. 9010/Mum/2025 (Assessment Year: 2017-18) 5. Ita No. 9011/Mum/2025 (Assessment Year: 2019-20) & 6. Ita No. 9012/Mum/2025 (Assessment Year: 2020-21) Swd Industries, Pcit (Central), 1402, South Tower 25, Mumbai-1, South Prabhadevi, Vs. R. No. 1001, 10Th Mumbai-400 025 Floor, Pratistha Bhavan, Old Cgo Annexe, Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aaofs8319L (Applicant) (Respondent) Assessee By Shri Salil Kapoor A/W Shri Sumit Lalchandani, Shri Shivam Yadav, Shri Shri Vinod Gupta, Ld. Ars Revenue By Shri Vivek Perampurna, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 143(3)Section 153CSection 153DSection 263

assessee and passed assessment orders determining the total income for the respective years. In some of the years, the Assessing Officer made disallowance of interest expenditure claimed by the assessee, while in other years the returned income was accepted. The assessments so framed were passed by the Assessing Officer after

Swd Industries, Mumbai vs. PCIT (Central), Mumbai-1, Mumbai

In the result, all the appeals filed by the assessee for the respective assessment years are allowed, and the impugned orders passed by the learned PCIT under section 263 of the Act are set aside

ITA 9010/MUM/2025[2017-2018]Status: DisposedITAT Mumbai12 Mar 2026AY 2017-2018

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 9007/Mum/2025 (Assessment Year: 2014-15) 2. Ita No. 9008/Mum/2025 (Assessment Year: 2015-16) 3. Ita No. 9009/Mum/2025 (Assessment Year: 2016-17) 4. Ita No. 9010/Mum/2025 (Assessment Year: 2017-18) 5. Ita No. 9011/Mum/2025 (Assessment Year: 2019-20) & 6. Ita No. 9012/Mum/2025 (Assessment Year: 2020-21) Swd Industries, Pcit (Central), 1402, South Tower 25, Mumbai-1, South Prabhadevi, Vs. R. No. 1001, 10Th Mumbai-400 025 Floor, Pratistha Bhavan, Old Cgo Annexe, Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aaofs8319L (Applicant) (Respondent) Assessee By Shri Salil Kapoor A/W Shri Sumit Lalchandani, Shri Shivam Yadav, Shri Shri Vinod Gupta, Ld. Ars Revenue By Shri Vivek Perampurna, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 143(3)Section 153CSection 153DSection 263

assessee and passed assessment orders determining the total income for the respective years. In some of the years, the Assessing Officer made disallowance of interest expenditure claimed by the assessee, while in other years the returned income was accepted. The assessments so framed were passed by the Assessing Officer after

Swd Industries, Mumbai vs. PCIT (Central), Mumbai-1, Mumbai

In the result, all the appeals filed by the assessee for the respective assessment years are allowed, and the impugned orders passed by the learned PCIT under section 263 of the Act are set aside

ITA 9009/MUM/2025[2016-2017]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-2017

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 9007/Mum/2025 (Assessment Year: 2014-15) 2. Ita No. 9008/Mum/2025 (Assessment Year: 2015-16) 3. Ita No. 9009/Mum/2025 (Assessment Year: 2016-17) 4. Ita No. 9010/Mum/2025 (Assessment Year: 2017-18) 5. Ita No. 9011/Mum/2025 (Assessment Year: 2019-20) & 6. Ita No. 9012/Mum/2025 (Assessment Year: 2020-21) Swd Industries, Pcit (Central), 1402, South Tower 25, Mumbai-1, South Prabhadevi, Vs. R. No. 1001, 10Th Mumbai-400 025 Floor, Pratistha Bhavan, Old Cgo Annexe, Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aaofs8319L (Applicant) (Respondent) Assessee By Shri Salil Kapoor A/W Shri Sumit Lalchandani, Shri Shivam Yadav, Shri Shri Vinod Gupta, Ld. Ars Revenue By Shri Vivek Perampurna, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 143(3)Section 153CSection 153DSection 263

assessee and passed assessment orders determining the total income for the respective years. In some of the years, the Assessing Officer made disallowance of interest expenditure claimed by the assessee, while in other years the returned income was accepted. The assessments so framed were passed by the Assessing Officer after

Swd Industries, Mumbai vs. PCIT (Central), Mumbai-1, Mumbai

In the result, all the appeals filed by the assessee for the respective assessment years are allowed, and the impugned orders passed by the learned PCIT under section 263 of the Act are set aside

ITA 9008/MUM/2025[2015-2016]Status: DisposedITAT Mumbai12 Mar 2026AY 2015-2016

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 9007/Mum/2025 (Assessment Year: 2014-15) 2. Ita No. 9008/Mum/2025 (Assessment Year: 2015-16) 3. Ita No. 9009/Mum/2025 (Assessment Year: 2016-17) 4. Ita No. 9010/Mum/2025 (Assessment Year: 2017-18) 5. Ita No. 9011/Mum/2025 (Assessment Year: 2019-20) & 6. Ita No. 9012/Mum/2025 (Assessment Year: 2020-21) Swd Industries, Pcit (Central), 1402, South Tower 25, Mumbai-1, South Prabhadevi, Vs. R. No. 1001, 10Th Mumbai-400 025 Floor, Pratistha Bhavan, Old Cgo Annexe, Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aaofs8319L (Applicant) (Respondent) Assessee By Shri Salil Kapoor A/W Shri Sumit Lalchandani, Shri Shivam Yadav, Shri Shri Vinod Gupta, Ld. Ars Revenue By Shri Vivek Perampurna, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 143(3)Section 153CSection 153DSection 263

assessee and passed assessment orders determining the total income for the respective years. In some of the years, the Assessing Officer made disallowance of interest expenditure claimed by the assessee, while in other years the returned income was accepted. The assessments so framed were passed by the Assessing Officer after

Swd Industries, Mumbai vs. PCIT (Central), Mumbai-1, Mumbai

In the result, all the appeals filed by the assessee for the respective assessment years are allowed, and the impugned orders passed by the learned PCIT under section 263 of the Act are set aside

ITA 9007/MUM/2025[2014-2015]Status: DisposedITAT Mumbai12 Mar 2026AY 2014-2015

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 9007/Mum/2025 (Assessment Year: 2014-15) 2. Ita No. 9008/Mum/2025 (Assessment Year: 2015-16) 3. Ita No. 9009/Mum/2025 (Assessment Year: 2016-17) 4. Ita No. 9010/Mum/2025 (Assessment Year: 2017-18) 5. Ita No. 9011/Mum/2025 (Assessment Year: 2019-20) & 6. Ita No. 9012/Mum/2025 (Assessment Year: 2020-21) Swd Industries, Pcit (Central), 1402, South Tower 25, Mumbai-1, South Prabhadevi, Vs. R. No. 1001, 10Th Mumbai-400 025 Floor, Pratistha Bhavan, Old Cgo Annexe, Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aaofs8319L (Applicant) (Respondent) Assessee By Shri Salil Kapoor A/W Shri Sumit Lalchandani, Shri Shivam Yadav, Shri Shri Vinod Gupta, Ld. Ars Revenue By Shri Vivek Perampurna, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 143(3)Section 153CSection 153DSection 263

assessee and passed assessment orders determining the total income for the respective years. In some of the years, the Assessing Officer made disallowance of interest expenditure claimed by the assessee, while in other years the returned income was accepted. The assessments so framed were passed by the Assessing Officer after

Ufx Ventures Pvt. Ltd., Chennai vs. ACIT, Corporate Circle-3(2), Chennai

In the result, the appeals filed by the assessee are

ITA 2273/CHNY/2025[2014-15]Status: DisposedITAT Chennai11 Mar 2026AY 2014-15

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Ms. Shilpa Susan Kuriachan, CAFor Respondent: Ms. T. Mythili, JCIT
Section 143(3)Section 250Section 37

vide order dated 30.03.2016. In the assessment order, the AO made additions amounting to Rs.2,91,00,718/- under various heads, including disallowance of interest expenditure amounting to Rs.2,74,49,888/-. 4. Aggrieved, assessee filed appeal before the First Appellate Authority (FAA). As regards interest disallowance of Rs.2 ... have heard the rival submissions and perused the materials available on record. The issue involved in the present appeal relates to the disallowance of interest expenditure amounting to Rs.2,74,49,888/- made by the AO. The FAA confirmed the addition of Rs.2,73,73,313/-. The contention

Ufx Ventures Pvt. Ltd., Chennai vs. ACIT, Corporate Circle-3(2), Chennai

In the result, the appeals filed by the assessee are

ITA 2272/CHNY/2025[2013-14]Status: DisposedITAT Chennai11 Mar 2026AY 2013-14

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Ms. Shilpa Susan Kuriachan, CAFor Respondent: Ms. T. Mythili, JCIT
Section 143(3)Section 250Section 37

vide order dated 30.03.2016. In the assessment order, the AO made additions amounting to Rs.2,91,00,718/- under various heads, including disallowance of interest expenditure amounting to Rs.2,74,49,888/-. 4. Aggrieved, assessee filed appeal before the First Appellate Authority (FAA). As regards interest disallowance of Rs.2 ... have heard the rival submissions and perused the materials available on record. The issue involved in the present appeal relates to the disallowance of interest expenditure amounting to Rs.2,74,49,888/- made by the AO. The FAA confirmed the addition of Rs.2,73,73,313/-. The contention

Asst. Commissioner of Income Tax, Mumbai vs. Reliance Retail Limited, Mumbai

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is partly allowed

ITA 4244/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C

crore. On these facts, the learned CIT(A) held that the investments were fully covered by interest-free funds and therefore no disallowance of interest expenditure was warranted. While arriving at this conclusion, the learned CIT(A) relied upon the decision of the Hon’ble Bombay High Court ... presumption laid down by the Hon’ble Bombay High Court squarely applies and the conclusion drawn by the learned CIT(A) that no disallowance of interest expenditure was warranted does not call for any interference. 29. We also find merit in the submission of the learned AR that the learned

Reliance Retail Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 8(1)(1), Mumbai

ITA 3510/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C

crore. On these facts, the learned CIT(A) held that the investments were fully covered by interest-free funds and therefore no disallowance of interest expenditure was warranted. While arriving at this conclusion, the learned CIT(A) relied upon the decision of the Hon'ble Bombay High Court ... presumption laid down by the Hon'ble Bombay High Court squarely applies and the conclusion drawn by the learned CIT(A) that no disallowance of interest expenditure was warranted does not call for any interference. 29. We also find merit in the submission of the learned AR that the learned

ACIT CC 7(3), Mumbai vs. Nop Properties Private Limited, Mumbai

In the result, the appeal of Revenue is dismissed

ITA 7648/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Mar 2026AY 2012-13

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarassistant Commissioner Of V/S. Nop Properties Private Income Tax, Central Circle – बनाम Limited 7(3), Room No. 655, 6Th Floor, Office No. Ii-B, Mezzanine Aayakar Bhavan, M.K. Road, Floor, 289 Emca House, Shahid Mumbai – 400 020, Bhagat Singh Road, Fort, Maharashtra Mumbai – 400 001, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcn1799B Appellant/अपीलाथी .. Respondent/प्रतिवादी

For Appellant: Shri Rahul Punmiya, ARFor Respondent: Shri Brajendra Kumar (Sr. DR)
Section 132Section 143(3)Section 147Section 148Section 68

Income Tax Act, 1961 of Rs. 25,00,000/- being accommodation entries received from M/s. Khusboo Complex Pvt. Ltd. and deleting the disallowance of interest expenditure of Rs. 2,049/- incurred towards accommodation entries, without appreciating that it was established during the search action and was admitted

Metrik Infra Projects Private Limited, Bangalore vs. Income Tax Officer, Ward-4(1)(4), Bangalore

In the result, the appeal filed by the assessee is dismissed as infructuous

ITA 125/BANG/2025[2017-18]Status: DisposedITAT Bangalore02 Mar 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 142(1)Section 143(2)Section 234Section 37Section 9

purpose of business, thus the expenditure deserves to be allowed on the facts and circumstances of the case. 7. Grounds on disallowance of interest expenditure on delayed TDS remittance, Rs.1,27,523/-: a. The authorities below have failed to appreciate that the interest expenditure incurred on delayed remittance

Shaileshkumar Dahyabhai Patel, Vadodara, Gujarat vs. Deputy Commissioner of Income Tax Circle 2(1)(2) (Now DCIT Circle 2(1)(1), Vadodara, Gujarat

In the result, Ground Number 7 of the assessee’s appeal is allowed

ITA 2131/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Milin Mehta & Shri Bhavin Marfatia, ARsFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 234BSection 234CSection 270ASection 271ASection 272A(1)(b)Section 6Section 68Section 69ASection 69C

section 68 of the Act and he confirmed the addition of ₹60,50,000/- as unexplained cash credits. 6. In relation to the disallowance of interest expenditure of ₹8,98,956/- under section 69C of the Act, the Ld. CIT(Appeals) held that once the principal loan itself was held ... sustainable. Accordingly, Ground No. 5 raised by the assessee is allowed. 15. Ground No. 6 relates to the disallowance of interest expenditure of ₹8,98,956/- under section 69C of the Act with respect to the above unsecured loans. Since this disallowance is consequential to and directly connected with

ACIT Central Circle 2(3), Ahmedabad vs. Intas Pharmaceuticals Limited, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

Section 250

Accordingly, Ground No. 14 is dismissed. Ground No. 15 – Disallowance under Section 36(1)(iii) 10. This ground relates to deletion of disallowance of interest expenditure made by the Assessing Officer under section 36(1)(iii) of the Act on account of alleged utilization of borrowed funds for capital work

Channamma Rachappa Saradagi, Bagalkot vs. Income Tax Officer, Ward-6(3)(1), Bangalore

Appeal of the assessee is partly allowed

ITA 2065/BANG/2025[2022-23]Status: DisposedITAT Bangalore23 Feb 2026AY 2022-23

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2022-23 Mrs. Channamma Rachappa Saradagi, Vs. The Income Tax Officer, Prop. M/S. Srinidhi Transports, Ward 6(3)(1), Sangondeshwar Nagar, Kamatagi, Bangalore. Amingad, Bagalkot – 587 120. Pan: Aweps 8300D Appellant Respondent Appellant By : Shri Siddesh N Gaddi, Ca Respondent By : Shri K. Saravanan, Addl.Cit (Dr)(Itat), Bengaluru. Date Of Hearing : 28.01.2026 Date Of Pronouncement : 23.02.2026 O R D E R Per Prashant Maharishi1. Captioned Appeal For Ay 2022-23 Is Filed By Mrs. Channamma Rachappa Saradagi Against The Appellate Order Passed By The National Faceless Appeal Centre, Delhi (Nfac) [Ld. Cit(A)] Dated 29 August 2025 Wherein The Appeal Filed By The Assessee Against The Assessment Order Dated 22Nd Of March 2024 Passed Under Section 143 (3) Read With Section 144B Of The Income Tax Act, 1961 [The Act] Passed By The Learned Assessing Officer Was Dismissed. Therefore The Assessee Is In Appeal Before Us. Page 2 Of 11

For Appellant: Shri Siddesh N Gaddi, CAFor Respondent: Shri K. Saravanan, Addl.CIT (DR)(ITAT), Bengaluru
Section 143Section 144BSection 36Section 37(1)Section 68

received during the year. Accordingly ground No. 4 – 13 of the appeal are allowed as indicated above. 20. Next with respect to the disallowance of interest expenditure of Rs.221,518 being interest expenditure on gold loan and MSME loan obtained by the assessee. It is the claim of the assessee

ACIT-4(3)(1), Mumbai vs. Qmax Synthetics Private Limited, Mumbai

ITA 7561/MUM/2025[2012-13]Status: DisposedITAT Mumbai20 Feb 2026AY 2012-13
For Appellant: Shri Ashok BansalFor Respondent: Shri Annavaran Kosuri
Section 143(3)Section 147Section 148Section 37(1)Section 68Section 69C

Pravin Kumar Jain group on 01.10.2013, constituting fresh tangible material for this assessment year. 3. The Ld. CITIA) erred in deleting the disallowance of interest expenditure of Rs.2,63,243/- (comprising Rs. 1,74,641/- paid to Olive Overseas Put. Ltd. and Rs.88,602/- to other non-genuine lenders), without ... 4378/Mum/2017 dated 27.04.2022,which held in favour of the appellant by deleting the entire addition under section 68 as well as the disallowance of interest expenditure. The ITAT's findings in the said order are reproduced below for reference: "5. Heard both the sides and perused the material on record

DCIT 2(3)(1), Mumbai vs. Tata Steel Ltd, Mumbai

In the result, appeal of the Revenue is dismissed and that of the assessee is allowed

ITA 3555/MUM/2016[2008-09]Status: DisposedITAT Mumbai20 Feb 2026AY 2008-09
For Appellant: Shri J.D. Mistri, Sr. Advocate and Ms. Jasmin Amalsadvala, AdvocateFor Respondent: Shri Ajay Chandra, CIT DR
Section 143(3)Section 144Section 147Section 148Section 151Section 36(1)(iii)Section 57

case of CIT vs. Amritaben R. Shah [1999] 238 ITR 777 (Bom). He thus, concluded by taking an adverse view to make the disallowance of interest expenditure amounting to Rs. 518,75,84,534/- and added it to the total income of the assessee. 11. It is important to take