← All Phrases

“Section 36(1)(iii)”

Section References (mined)Section 36Section 36(1)(iii)1,547 judgments

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

Leading authorities on Section 36(1)(iii)

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.

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.

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.

Maxopp Investment Ltd. v. CIT
347 ITR 272 · 2012 · High Court
516
citing judgments

Disallowance under Section 14A cannot exceed the exempt income earned. The Assessing Officer must record satisfaction regarding the assessee's accounts before making any disallowance.

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.

Judgments citing Section 36(1)(iii)

Neminath Industries Pvt. Ltd., New Delhi vs. ITO, Ward- 18(1), New Delhi

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

ITA 6484/DEL/2017[2013-14]Status: DisposedITAT Delhi06 Dec 2024AY 2013-14

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2013-14]

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

purpose of business. The AO therefore held that the reply of the assessee fails on both the conditions laid down in section 36(1)(iii) of the Act and disallowed the interest of Rs.47,03,222/- and added to the total income of the assessee. 4. Against the above order

Vision India Colonizers Private Limited, Mohali vs. ITO, Ward 6(4), Mohali

In the result, appeal of the Assessee is allowed

ITA 90/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh04 Dec 2024AY 2013-14

Bench: SHRI. SANJAY GARG (Judicial Member)

For Appellant: Shri Deepak Aggarwal, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 250(6)Section 36(1)(iii)

appeal is hereby condoned. 4. The sole issue involved in this appeal is relating to the addition made by the lower authorities under section 36(1)(iii) of the Income Tax Act, 1961 of Rs. 17,40,308/- on account of notional interest on free advances given by the assessee ... that since the assessee had deep interest in the business prospectives of associate concern. He, therefore, has contended that the provisions of Section 36(1)(iii) were not applicable in this case. 6. I find that the Ld. CIT(A) has rejected the contention of the assessee on the ground

DCIT Pondicherry Circle, Pondicherry vs. Ravikumar Distilleries Ltd., Pondicherry

Accordingly. The ground stand partly allowed

ITA 1395/CHNY/2018[2012-13]Status: DisposedITAT Chennai03 Dec 2024AY 2012-13

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1.आयकरअपील सं./ Ita No.974/Chny/2018 (िनधा)रणवष) / Assessment Year: 2012-13) M/S. Ravikumar Distilleries Limited Dcit बनाम/ #17, Kamaraj Salai, Pondicherry Circle, Vs. Pondicherry-605 011. Puducherry-605 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aabcr-4195-D (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2.आयकरअपील सं./ Ita No.1395/Chny/2018 (िनधा)रणवष) / Assessment Year: 2012-13) Dcit M/S. Ravikumar Distilleries Limited बनाम Pondicherry Circle, # C-9 & C-10, Industrial Estate, / Vs. Puducherry-605 001. Thattanchavady, Pondicherry-605 009. "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aabcr-4195-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Assessee By : Shri N. Arjun Raj (Advocate) - Ld.Ar " थ"कीओरसे/Revenue By : Shri A.Sasikumar (Cit) - Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 21-11-2024 घोषणाकीतारीख /Date Of Pronouncement : 03-12-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri N. Arjun Raj (Advocate) - ld.ARFor Respondent: Shri A.Sasikumar (CIT) - Ld. Sr. DR
Section 143(3)Section 14ASection 194JSection 36(1)(iii)Section 40Section 69

आयकर अपीलीय अिधकरण “डी” "ायपीठ चे"ई म"। IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, CHENNAI माननीय "ी मनोज कुमार

Simoco Systems and Infrastructure Solutions Limited, Kolkata vs. ITO Ward 2 (1), Kolkata

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

ITA 123/KOL/2024[2018-19]Status: DisposedITAT Kolkata29 Nov 2024AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Year: 2018-19

For Appellant: Indranil Banerjee, ARFor Respondent: Ankur Goyal, JCIT, Sr. DR
Section 115JSection 133(6)Section 143(3)Section 144BSection 250

whether this was done as a measure of commercial expediency. [Para 21] The decisions relating to section 37 will also be applicable to section 36(1)(iii) be- cause in section 37 also the expression used is 'for the purpose of business'. It has been consistently held in decisions relating ... that the borrowed fund advanced to a third party should be for commercial expediency, if it is sought to be allowed under section 36(1)(iii). [Para 27] In the instant case, neither the High Court nor the Tribunal and other authorities had examined whether the amount advanced

Gpa Capital Foods Private Limited, Delhi vs. Assistant Commissioner of Income Tax (OSD), Circle 10, Delhi

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

ITA 2846/DEL/2024[2018-19]Status: DisposedITAT Delhi29 Nov 2024AY 2018-19

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumargpa Capital Foods Pvt. Assistant Limited Vs Commissioner Of Income Tax (Osd), F-1734-1735, Dsiidc . Industrial Area, Narela Circle-10, Delhi-110 040 Delhi-110 002 Pan : Aajca 1965 A (Appellant) (Respondent)

Section 142(1)Section 143(2)Section 143(3)Section 36(1)(iii)Section 40A(2)Section 40A(2)(b)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’: NEW DELHI BEFORE SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER AND SHRI

Chandrakumar Madhusudanji Jajodia, Thane vs. Assistant Commissioner of Income Tax, Amravati Circle

In the result, appeal filed by the assessee is allowed

ITA 399/NAG/2023[2013-14]Status: DisposedITAT Nagpur28 Nov 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Abhay Y. Marathe
Section 143(2)Section 143(3)Section 144Section 148Section 234ASection 36(1)(iii)Section 68Section 69A

unjustified, unwarranted and bad in law. 7. The learned CIT(A) ought to have deleted the addition of Rs.1,99,520/- assessed under section 36(1)(iii) of I.T. Act 1961 in respect to interest paid to M/s Abhilasha Shoppers Pvt. Ltd. 8. The assessee denies liability to pay interest

Deputy Commissioner of Income Tax, Central Circle-3, Jaipur vs. Naresh Kumar Gupta, Sriganganagar

In the results the appeal of the revenue stands dismissed and the

ITA 458/JPR/2024[2014-15]Status: DisposedITAT Jaipur28 Nov 2024AY 2014-15

Bench: Him The Order Passed Under Section 143(3) Of The Income Tax Act, [ For Short “Act” ] By The Acit, Circle, Sri Ganganagar [

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Ms. Alka Gautam (CIT) (V.H.)
Section 143(3)Section 14ASection 36(1)(iii)

with Rule 8D of the Act. The remaining amount of interest at Rs.97,63,413/- was disallowed in view of the provisions of section 36(1) (iii) of the Act as also in view of the judgments of Hon'ble Superme Court in the case of S.A. Builders and that

Siwana Agri Marketing Limited (Now Merged With Vital Connections LLP), Ahmedabad vs. Assistant Commissioner of Income Tax, Circle 4(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1094/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad27 Nov 2024AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1094/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Siwana Agri Marketing Ltd. The Acit बनाम/ (Now Merged With Vital Circle-4(1)(1) V/S. Connections Llp) Ahmedabad 401, Ashopalav Apartments Near Suvidha Shopping Centre Paldi Ahmedabad – 380 007 (Gujarat) "थायी लेखा सं./Pan: Aaccs 9598 J (अपीलाथ&/ Appellant) ('( यथ&/ Respondent) Assessee By : Shri Prakash D. Shah, Ar Revenue By : Shri Atul Pandey, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 25/11/2024 घोषणा की तारीख /Date Of Pronouncement: 27/11/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri Prakash D. Shah, ARFor Respondent: Shri Atul Pandey, Sr.DR
Section 143(3)Section 250Section 36(1)(iii)Section 36(2)

determining total income at Rs.97,85,762/-. 2.1. The AO disallowed Rs.65,86,200/- under Section 36(1)(iii) of the Act, observing that the assessee had advanced interest-free loans amounting to Rs.5.48 crores while incurring significant interest expenses on unsecured borrowings. The AO held that the assessee failed ... learned National Faceless Appeal Centre has erred in law and facts by confirming the disallowance of interest expense of Rs.65,86,200/- under section 36(1)(iii) of the Act and therefore the learned AO be directed to allow the interest expense while computing Total Income. 2. The learned National

Income Tax Officer, Ward-9(1), Kolkata vs. Kali Fabrics Private Limited, Kolkata

In the result, appeal of the revenue is dismissed

ITA 291/KOL/2024[2018]Status: DisposedITAT Kolkata27 Nov 2024

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm]

Section 143(2)Section 143(3)Section 36Section 36(1)(iii)

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, KOLKATA [Before Shri Rajesh Kumar, AM & Shri Sonjoy Sarma, JM] I.T.A. No

Income Tax Officer, Ward 7(2)(1), Mumbai, Income Tax Department vs. Monarch Technobuild Private Limted, Mumbai

In the result, the appeal of Revenue as well as the Cross

ITA 1287/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 Nov 2024AY 2012-13

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail: A.Y. : 2012-13 C.O. No. 172/Mum/2024 A.Y. : 2012-13 (Arising Out Of Ita No. 1287/M/24)

For Appellant: Shri Snehal ShahFor Respondent: Shri Sunil A. Umap, CIT-DR
Section 143(1)Section 148Section 68Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F”, MUMBAI BEFORE SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER AND SHRI SANDEEP

Technodot Engineers Pvt. Ltd, Gandhinagar vs. The DCIT, Circle-2(2), Ahmedabad

Appeals of the assessee are partly allowed for statistical purposes

ITA 93/AHD/2020[2011-12]Status: DisposedITAT Ahmedabad26 Nov 2024AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokari.T(Ss).A. Nos.147&148/Ahd/2019 (A.Ys.: 2005-06 & 2006-07) Smt. Neelu Sanjay Gupta, Vs. Deputy Commissioner Of L/H. Of Late Shri Sanjay Gupta Income Tax, B-202, Dhananjay Tower, Central Circle-2(2), Anand Nagar Road, Satellite, Ahmedabad Ahmedabad-380015 [Pan No.Adypg0351K] (Appellant) .. (Respondent) I.T(Ss).A. Nos.21 To 23/Ahd/2020 & 15/Ahd/2022 & Ita No. 93/Ahd/2020) (A.Ys.: 2007-08, 2008-09 & 2006-07 & 2010-11 To 2011-12) M/S. Technodot Engineers Ltd., Vs. Deputy Commissioner Of C/O. Cambay Hotel & Resorts, Income Tax, Plot No. 22, 23, 24 Gidc, Central Circle-2(2), Sector-25, Gandhinagar-382010 Ahmedabad [Pan No.Aabct5392A] (Appellant) .. (Respondent)

For Appellant: Shri Tushar Hemani, Sr. Adv. & Shri ParimalFor Respondent: Shri R. N. Dsouza, CIT-DR & Shri Rignesh K
Section 132Section 139(1)Section 142Section 142(1)Section 143(2)Section 153ASection 271(1)(b)

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER & SHRI MAKARAND V. MAHADEOKAR, ACCOUNTANT

Dy. Commissioner of Income Tax, Aayakar Bhawan vs. Rockman Industries Limited, Focal Point

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 84/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh25 Nov 2024AY 2020-21

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

while calculating the capitalization of interest. 10. If your honour held that the interest is to be capitalized as per proviso to section 36(1)(iii), then the addition should be considered separately while computing the income of Haridwar Unit for allowing the deduction u/s 80IC ... assets which have not been put to use for business purposes cannot be allowed as revenue expenses in view of provision of section 36(1)(iii) of the Act and needs to be capitalized. On the Other hand, the assessee company has submitted that the assessee company has not borrowed

Asstt. Commissioner of Income Tax, Circle-4, Aayakar Bhawan vs. Rockman Industries Limited

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 177/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh25 Nov 2024AY 2013-14

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

while calculating the capitalization of interest. 10. If your honour held that the interest is to be capitalized as per proviso to section 36(1)(iii), then the addition should be considered separately while computing the income of Haridwar Unit for allowing the deduction u/s 80IC ... assets which have not been put to use for business purposes cannot be allowed as revenue expenses in view of provision of section 36(1)(iii) of the Act and needs to be capitalized. On the Other hand, the assessee company has submitted that the assessee company has not borrowed

Dy. Commissioner of Income Tax, Circle-4, Ludhiana vs. Rockman Industries Ltd

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 818/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh25 Nov 2024AY 2015-16

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

while calculating the capitalization of interest. 10. If your honour held that the interest is to be capitalized as per proviso to section 36(1)(iii), then the addition should be considered separately while computing the income of Haridwar Unit for allowing the deduction u/s 80IC ... assets which have not been put to use for business purposes cannot be allowed as revenue expenses in view of provision of section 36(1)(iii) of the Act and needs to be capitalized. On the Other hand, the assessee company has submitted that the assessee company has not borrowed

Dy. Commissioner of Income Tax, Circle-4, Aayakar Bhawan vs. Rockman Industries Limited

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 817/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh25 Nov 2024AY 2014-15

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

while calculating the capitalization of interest. 10. If your honour held that the interest is to be capitalized as per proviso to section 36(1)(iii), then the addition should be considered separately while computing the income of Haridwar Unit for allowing the deduction u/s 80IC ... assets which have not been put to use for business purposes cannot be allowed as revenue expenses in view of provision of section 36(1)(iii) of the Act and needs to be capitalized. On the Other hand, the assessee company has submitted that the assessee company has not borrowed

Dy. Commissioner of Income Tax, Circle-4, Ludhiana, Aayakar Bhawan vs. Rockman Industries Limited

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 796/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh25 Nov 2024AY 2018-19

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

while calculating the capitalization of interest. 10. If your honour held that the interest is to be capitalized as per proviso to section 36(1)(iii), then the addition should be considered separately while computing the income of Haridwar Unit for allowing the deduction u/s 80IC ... assets which have not been put to use for business purposes cannot be allowed as revenue expenses in view of provision of section 36(1)(iii) of the Act and needs to be capitalized. On the Other hand, the assessee company has submitted that the assessee company has not borrowed

Dy. Commissioner of Income Tax, Circle-4, Aayakar Bhawan vs. Rockman Industries Limited

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 795/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh25 Nov 2024AY 2017-18

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

while calculating the capitalization of interest. 10. If your honour held that the interest is to be capitalized as per proviso to section 36(1)(iii), then the addition should be considered separately while computing the income of Haridwar Unit for allowing the deduction u/s 80IC ... assets which have not been put to use for business purposes cannot be allowed as revenue expenses in view of provision of section 36(1)(iii) of the Act and needs to be capitalized. On the Other hand, the assessee company has submitted that the assessee company has not borrowed

Dy. Commissioner of Income Tax, Circle-4, Aayakar Bhawan vs. Rockman Industries Limited

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 794/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh25 Nov 2024AY 2016-17

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

while calculating the capitalization of interest. 10. If your honour held that the interest is to be capitalized as per proviso to section 36(1)(iii), then the addition should be considered separately while computing the income of Haridwar Unit for allowing the deduction u/s 80IC ... assets which have not been put to use for business purposes cannot be allowed as revenue expenses in view of provision of section 36(1)(iii) of the Act and needs to be capitalized. On the Other hand, the assessee company has submitted that the assessee company has not borrowed

DCIT Circle-4, Ludhiana vs. Rockman Industries Ltd, Ludhiana

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 748/CHANDI/2023[2010-11]Status: DisposedITAT Chandigarh25 Nov 2024AY 2010-11

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

while calculating the capitalization of interest. 10. If your honour held that the interest is to be capitalized as per proviso to section 36(1)(iii), then the addition should be considered separately while computing the income of Haridwar Unit for allowing the deduction u/s 80IC ... assets which have not been put to use for business purposes cannot be allowed as revenue expenses in view of provision of section 36(1)(iii) of the Act and needs to be capitalized. On the Other hand, the assessee company has submitted that the assessee company has not borrowed

Atul Krishna, Meerut vs. DCIT Central Circle, Meerut

In the result, the appeal of the assessee is allowed

ITA 1887/DEL/2024[2015-16]Status: DisposedITAT Delhi25 Nov 2024AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshatul Krishna, Vs. Dcit, 1, Ambedkar Bhawan, Central Circle, Subharti Puram, Meerut, Meerut Uttar Pradesh (Appellant) (Respondent) Pan:Aaypk2016J Assessee By : None Revenue By: Ms. Kanchan Garg, Sr. Dr Date Of Hearing 13/11/2024 Date Of Pronouncement 25/11/2024

For Appellant: NoneFor Respondent: Ms. Kanchan Garg, Sr. DR
Section 143(3)Section 36(1)(iii)Section 57Section 69A

also argued that assessee had indeed shown income from profession and hence the interest expenditure would be allowable as deduction even under section 36(1)(iii) of the Act. 5. The Learned CITA observed that assessee had also shown savings bank interest of Rs 2,10,045/- from bank