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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

Dinesh B Pokhriyal, Kalyan vs. ITO Ward(2) Panvel, Panvel

In the result, the appeal of the assessee is partly allowed as per the above terms

ITA 2396/PUN/2024[2010-11]Status: DisposedITAT Pune19 Jan 2026AY 2010-11

Bench: Shri Manish Boradआयकर अपील सं. / Ita No.2396/Pun/2024 िनधा"रण वष" / Assessment Year : 2010-11 Dinesh B. Pokhriyal, Vs. Ito, Ward- 2, Panvel. Flat No.306, 3Rd Floor, Cypress Building, Vasant Valley, Khadakpada, Kalyan(W)- 421301. Pan : Aerpp9652C Appellant Respondent Assessee By : Shri Dinesh B. Pokhriyal (Self) Revenue By : Shri Shashank Ojha (Virtual) Date Of Hearing : 13.01.2026 Date Of Pronouncement : 19.01.2026 आदेश / Order Per Manish Borad, Am: This Appeal Filed At The Instance Of Assessee Is Directed Against The Order Of Ld. Cit(A)/Nfac Dated 18.10.2024 Which Is Arising Out Of The Assessment Order U/S 143(3) Of The Act For Assessment Year 2010-11 Framed On 28.03.2013 By The Ito, Ward-2, Panvel. 2. The Assessee Has Raised Multiple Grounds Of Appeal Raising Legal Issues Challenging The Validity Of The Assessment Proceedings

For Appellant: Shri Dinesh B. Pokhriyal (Self)For Respondent: Shri Shashank Ojha (Virtual)
Section 133(6)Section 143(2)Section 143(3)

grounds of appeal raising legal issues challenging the validity of the assessment proceedings 2 and also raised the grounds on merit against the disallowance of interest expenditure claimed at Rs.8,61,629/-. 3. At the outset, during the course of hearing, Ld. assessee requested for not pressing the legal grounds ... sole grievance of the assessee raised against the findings of Ld. CIT(A)/NFAC confirming the action of Ld. Assessing Officer disallowing the interest expenditure of Rs.8,61,629/-. 5. Brief fact of the case are that the assessee is an individual and declared income of Rs.8