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“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)

Yashu Iron Private Limited, Delhi vs. Deputy Commissioner of Income Tax. Central Circle 32, Delhi

In the result, the appeal of the assessee is allowed

ITA 6420/DEL/2025[2019-20]Status: DisposedITAT Delhi29 Jan 2026AY 2019-20

Bench: Shri Mahavir Singh, Hon’Ble & Smt. Renu Jauhri, Hon’Bleasstt. Year : 2019-20 Yashu Iron Private Limited, Vs. Dcit, Cc-32, Delhi 316, Pocket-8, Dda Multi Storey Building, Dwarka, Sector-12, Delhi – 110 075 (Pan: Aaacy4556E) (Appellant) (Respondent) Appellant By : Sh. S.K. Gupta, Ca Respondent By : Sh. Ajay Kumar Arora, Sr. Dr

For Appellant: Sh. S.K. Gupta, CAFor Respondent: Sh. Ajay Kumar Arora, Sr. DR
Section 147Section 36(1)(iii)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘A’ : NEW DELHI) BEFORE SHRI MAHAVIR SINGH, HON’BLE VICE PRESIDENT AND

Assistant Commissioner of Income Tax, Circle-25(1), New Delhi, Delhi vs. Techno Trexim India Pvt. Ltd., Delhi

In the result, appeal filed by the assessee is dismissed

ITA 582/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Jan 2026AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar Uss.

For Appellant: Shri I.P. Bansal, AdvocateFor Respondent: Shri Abhijeet Kumar, Sr.DR
Section 37

fixed assets and hence not available for making investment in shares of more than 45 crore in group companies. The AO referred to section 36(1)(iii) of the LT. Act to point out that the amount of interest paid in respect of capital borrowed for the purpose of business ... paid by the assessee on loans relating to investment in shares is dis-allowable 11 ITA No.468/Del/2024 ITA No.582/Del/2024 u/s 14A r.w.r.8D and section 36(1)(iii) of the Act was not invoked on similar facts earlier or later assessment proceedings of AY 2017-18 . The assessee has claimed that

Techno Trexim (India) Private Limited, New Delhi vs. ACIT, Circle- 25(1), Delhi

In the result, appeal filed by the assessee is dismissed

ITA 468/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Jan 2026AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar Uss.

For Appellant: Shri I.P. Bansal, AdvocateFor Respondent: Shri Abhijeet Kumar, Sr.DR
Section 37

fixed assets and hence not available for making investment in shares of more than 45 crore in group companies. The AO referred to section 36(1)(iii) of the LT. Act to point out that the amount of interest paid in respect of capital borrowed for the purpose of business ... paid by the assessee on loans relating to investment in shares is dis-allowable 11 ITA No.468/Del/2024 ITA No.582/Del/2024 u/s 14A r.w.r.8D and section 36(1)(iii) of the Act was not invoked on similar facts earlier or later assessment proceedings of AY 2017-18 . The assessee has claimed that

Chartered Speed Limited, Ahmedabad vs. DCIT Circle 1(1)(1), Ahmedabad

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

ITA 2286/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad28 Jan 2026AY 2014-15

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 14ASection 271(1)(c)Section 36(1)(iii)

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “B” BENCH Before: Shri T.R. Senthil Kumar, Judicial Member And Shri Narendra Prasad

DCIT, Central Circle-4(3), Kolkata vs. Golden Goenka Credit Private Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 1799/KOL/2025[2022-23]Status: DisposedITAT Kolkata28 Jan 2026AY 2022-23

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

Section 127Section 132(1)Section 139Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 36(1)(iii)Section 68

आयकर अपील"य अ"धकरण, कोलकाता पीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH KOLKATA Before Shri Rajesh

M/S Knitwell India Pvt. Ltd., Chandigarh vs. DCIT, C-1(1), Chandigarh

In the result, appeal of the assessee is partly allowed

ITA 1609/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh27 Jan 2026AY 2014-15

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1609/Chd/2018 "नधा"रण वष" / Assessment Year. : 2014-15 M/S Knitwell India Pvt. Ltd., The Dcit, Plot No. 278, Industrial Area, Vs Circle 1(1), Phase-Ii, Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Aacck4673L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Ms. Shruti Khandelwal, Advocate Revenue By : Shri Vivek Vardhan, Addl. Cit Sr.Dr Date Of Hearing : 24.11.2025 Date Of Pronouncement : 27.01.2026 O R D E R Physical Hearing Per Raj Pal Yadav, Vp

For Appellant: Ms. Shruti Khandelwal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr.DR
Section 143(2)Section 14ASection 36(1)(iii)

confirming the addition of Rs.5,38,557/- u/s 14A and addition of Rs.3,43,854/- which was added with the aid of Section 36(1)(iii) of the Income Tax Act. 4. The brief facts of the case are that assessee, at the relevant time was engaged in manufacturing

Deputy Commissioner of Income Tax, Pune vs. Vascon Engineers Limited, Pune

In the result, Appeal of the Revenue is Dismissed

ITA 1105/PUN/2025[2013-14]Status: DisposedITAT Pune27 Jan 2026AY 2013-14

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1105/Pun/2025 निर्धारण वषा / Assessment Years: 2013-14 Deputy Commissioner Vs. Vascon Engineers Limited, Of Income Tax, Pune. Vascon Weikfileld Chamber, Opposite Hyatt Hotel, Nagar Road, Pune – 411014. Pan: Aaacv1249F Appellant/ Revenue Respondent /Assessee Assessee By Shri Ajit Tolani & Darpan Kriplani Revenue By Smt. Indira R. Adakil – Addl.Cit(Dr) Date Of Hearing 02/12/2025 Date Of Pronouncement 27/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Revenue Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 05.02.2025Emanating From The Assessment Order Under Section 143(3) R.W.S 144C(3/4) Of The Act, 1961 Dated 23.01.2017 For The A.Y.2013-14. The Revenue Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 14ASection 14A(2)Section 250Section 36(1)(u)

आयकर अपीलीय अधिकरण ”बी” न्यायपीठ पुणेमें। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “B” :: PUNE BEFORE MS.ASTHA CHANDRA, JUDICIAL

Ladderup Finance Limited, Mumbai vs. Circle 14(1)(1), Mumbai

In the result the appeal filed by the assessee is allowed

ITA 7404/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Jan 2026AY 2015-16

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarladderup Finance Circle 14(1)(1), Limited Mumbai 1St Floor Hallmark Vs. Aayakar Bhavan, Business Plaza, Mumbai-400 020 Gurunanak Hospital Road, Bandra (East), Mumbai- 400051 Pan/Gir No. Aaacl0882G (Applicant) (Respondent) Assessee By Shri Rushabh Mehta Revenue By Shri Surendra Mohan, Sr. Dr Date Of Hearing 20.01.2026 Date Of Pronouncement 27.01.2026

Section 10(34)Section 10(38)Section 111ASection 115JSection 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 271(1)(c)

advances were made out of its own funds. Accordingly, interest 4 Ladderup Finance Limited expenditure of Rs. 7,08,213/- was disallowed under section 36(1)(iii) of the Act. 4.4. Further, a sum of Rs. 2,800/- was disallowed under section 94(7) of the Act on account ... already disallowed, Rule 8D was invoked without proper satisfaction, and disallowance under section 14A could not exceed exempt income. With respect to section 36(1)(iii), it was submitted that the advances were for business considerations and that additional disallowance over and above the amount agreed during assessment was unjustified

Warana Indusries Ltd, Kolhapur vs. Assistant Commissioner of Income-Tax, Circle - 1, Kolhapur

In the result, the appeal filed by the assessee is allowed for statistical purposes and the Cross Objection filed by the assessee is dismissed

ITA 1285/PUN/2019[2014-15]Status: DisposedITAT Pune22 Jan 2026AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15

For Appellant: None (written submissions filed)For Respondent: Shri Manish Mehta, Addl.CIT
Section 143(3)Section 36(1)Section 36(1)(iii)

that the same is paid against their credit balance / payable account or advance for purchases and therefore, no such disallowance and provision of section 36(1)(iii) of the Act are attracted. It is also the alternate submission of the assessee that the company has adequate interest-free funds

Ruchi Jain, Panipat vs. Assessing Officer, Panipat

In the result, the appeal of the assessee is allowed

ITA 6278/DEL/2025[2012-2013]Status: DisposedITAT Delhi22 Jan 2026AY 2012-2013

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Smt. Renu Jauhri, Hon’Ble

For Appellant: NoneFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 143(3)Section 147Section 250Section 36(1)(iii)

That the Learned CIT Appeal erred in law and facts in upholding the disallowance of interest amounting to Rs 75,61,721 under Section 36(1)(iii) of the Income Tax Act, 1961 without appreciating that the said amount was not an 1 ... contrary to facts and law and deserves to be set aside, and the disallowance of Rs 75,61,72/-1 made under Section 36(1)(iii) should be deleted in full. 8. That the impugned Assessment order passed by Ld. Assessing Officer, Noida is a clear cut case of misunderstanding

Vimal Alloys Private Limited, Mandi Gobindgarh, Punjab vs. Jao the Deputy Commissioner of Income Tax Circle, Patiala, Punjab

ITA 890/CHANDI/2025[2016-2017]Status: DisposedITAT Chandigarh21 Jan 2026AY 2016-2017

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Vipen Sethi, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 143(1)Section 147Section 148Section 151Section 69A

justified - Held, no [Para 11] [In favour of assessee] [2024] 159 taxmann.com 51 (Bombay)[29-01-2024] Section 37(1), read with sections 36(1)(iii), 36(1)(va), 43A and 147/148, of the Income-tax Act, 1961 - Business expenditure - Allowability of (Reassessment) - Assessment year 2015-16 - Assessee filed

Sri Rama Agri Genetics (India) Private Limited, Kurnool vs. DCIT., Circle-1, Kurnool

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

ITA 1179/HYD/2025[2015-16]Status: DisposedITAT Hyderabad21 Jan 2026AY 2015-16
Section 142(1)Section 143(3)Section 201Section 263Section 36(1)(iii)Section 36(1)(va)Section 41(1)Section 68

further disallowance of EPF & ESI under Section 36(1)(va) for Rs. 3,66,095/-, addition towards disallowance of interest expenditure under Section 36(1)(iii) for Rs. 11,08,678/-, disallowance of expenses claimed by the assessee under the head ‘trade discounts' and 'seed purchases' to the tune ... sustained additions made by the A.O. towards disallowance of interest on TDS, disallowance of EPF & ESI and disallowance of interest under Section 36(1)(iii) of the Act. The learned CIT(A) has also confirmed the addition made towards disallowance of seed purchases

DCIT, CC-1(4), Kolkata vs. Jupiter International Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 1678/KOL/2025[2014-15]Status: DisposedITAT Kolkata21 Jan 2026AY 2014-15

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2014-15 Dcit, Cc-1(4), Kolkata ………….……………………….……….……….……Appellant Vs. Jupiter International Limited..……………………………….....……...…..…..Respondent Unnayanam, 20A, Ashutosh Chowdhury Avenue, Kol-19.. [Pan: Aaacj6956B] Appearances By: Shri P. N Barnwal, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Soumitra Choudhury & Nandini Sureka, Advocate, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 12, 2026 Date Of Pronouncing The Order : January 21, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Revenue Is Directed Against The Order Dated 29.10.2024 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2014–15. 2. The Appeal Has Been Filed By The Revenue With A Delay Of 197 Days & The Revenue Has Filed A Petition For Condonation Of The Delay. After Going Over The Said Petition, We Find Sufficient Reasons Behind The Delay & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 132Section 142(1)Section 143(2)Section 14ASection 153ASection 250Section 56(2)Section 56(2)(viib)

view that the aforesaid amount of Rs. 11,42,572/- represent interest account and not provision. The same is allowable under section 36(1)(iii) of the Act. Accordingly, assessee's appeal on ground no 3 is allowed.” 8.1 We also find that the assessee pointed out that the report

DCIT, Mumbai vs. Sahyadri Agencies Limited, Moothedath House Arikanniyur

ITA 4257/MUM/2025[2018-19]Status: DisposedITAT Mumbai21 Jan 2026AY 2018-19

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(2)Section 14ASection 36(1)(iii)

circumstances of the case and in law, the Ld. CIT(A) has justified in deleting the disallowance of interest expenditure made under section 36(1)(iii) of the Income Tax Act, 1961, without appreciating that the borrowed funds were not utilized wholly and exclusively for the purposes of business ... borrowed funds were invested in shares held as investments and in other non-business advances, which do not qualify as business purposes under section 36(1)(iii)? 3. Whether on the facts and circumstances of the case and in law, the Ld.CIT(A) has justified in concluding that the interest

Assistant Commissioner of Income Tax, Central Revenue Building vs. M/S Hindustan Thermal Projects Limited, Delhi, India

Appeal is dismissed

ITA 5336/DEL/2025[2015-16]Status: DisposedITAT Delhi21 Jan 2026AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla

Section 143(3)Section 28Section 36(1)(iii)Section 37

grievance raised in the instant appeal that the CIT(A) has erred in law and on fact in reversing the assessment findings invoking section 36(1)(iii) interest disallowance of Rs.35 lakhs thereby alleging diversion of interest-bearing funds as non-business purposes, the lower appellate findings under challenge ... High Court as well as the authorities below on the aforesaid question was not correct. 19. In this connection we may refer to section 36(1)(iii) of the Income-tax Act, 1961 (hereinafter referred to as the 'Act') which states that "the amount of the interest paid in respect

New Star System Solution Private Limited, Delhi vs. DCIT, Circle-18(2), Delhi

In the result, appeal of the Assessee is accordingly allowed

ITA 3585/DEL/2025[2015-16]Status: DisposedITAT Delhi21 Jan 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 142(1)Section 143(2)Section 250Section 36(1)Section 36(1)(iii)

Income Tax Act, 1961 [hereinafter referred to as “the Act”] wherein assessment order dated 31.12.2016 was upheld and disallowance of expenses under section 36(1)(iii) of Rs. 3,46,87,318/- was confirmed. 2. The facts in brief as culled out from the order of the authorities below ... Star System Solution Pvt. Ltd. 296, the AO observed that the assessee would be entitled to deduction of interest under section 36(1)(iii) of the Act on the borrowed funds utilized for the acquisition of shares only if shares are held as stock-in- trade which arises only

Arunaben Kishorkumar Mandalia, Ahmedabad vs. The Pr.CIT, Central, Ahmedabad

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

ITA 1054/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad20 Jan 2026AY 2020-21

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita Nos. 1052 To 1054/Ahd/2025 िनधा"रण वष"/Asstt. Years: 2017-18 To 2020-21 Arunaben Kishorkumar Mandalia, The Principal बनामVs 12, Ashwamegh-Iii, Commissioner Of . 132 Feet Ring Road, Income Tax (Central), Satellite, Ahmedabad. Ahmedabad-380015. Pan: Ablpm2848Q (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri M K Patel, With Shri Vartik Choksi, Ars Revenue By : Shri Sher Singh, Cit.Dr

For Appellant: Shri M K Patel, with Shri Vartik Choksi, ARsFor Respondent: Shri Sher Singh, CIT.DR
Section 132Section 143(3)Section 153CSection 263

आयकर अपीलीय अिधकरण, अहमदाबाद "यायपीठ , अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “ D” BENCH, AHMEDABAD ] BEFORE SHRI SANJAY GARG, JUDICIAL

Arunaben Kishorkumar Mandalia, Ahmedabad vs. The Pr.CIT, Central, Ahmedabad

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

ITA 1053/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad20 Jan 2026AY 2018-19

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita Nos. 1052 To 1054/Ahd/2025 िनधा"रण वष"/Asstt. Years: 2017-18 To 2020-21 Arunaben Kishorkumar Mandalia, The Principal बनामVs 12, Ashwamegh-Iii, Commissioner Of . 132 Feet Ring Road, Income Tax (Central), Satellite, Ahmedabad. Ahmedabad-380015. Pan: Ablpm2848Q (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri M K Patel, With Shri Vartik Choksi, Ars Revenue By : Shri Sher Singh, Cit.Dr

For Appellant: Shri M K Patel, with Shri Vartik Choksi, ARsFor Respondent: Shri Sher Singh, CIT.DR
Section 132Section 143(3)Section 153CSection 263

आयकर अपीलीय अिधकरण, अहमदाबाद "यायपीठ , अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “ D” BENCH, AHMEDABAD ] BEFORE SHRI SANJAY GARG, JUDICIAL

Arunaben Kishorkumar Mandalia, Ahmedabad vs. The Pr.CIT, Central, Ahmedabad

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

ITA 1052/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad20 Jan 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita Nos. 1052 To 1054/Ahd/2025 िनधा"रण वष"/Asstt. Years: 2017-18 To 2020-21 Arunaben Kishorkumar Mandalia, The Principal बनामVs 12, Ashwamegh-Iii, Commissioner Of . 132 Feet Ring Road, Income Tax (Central), Satellite, Ahmedabad. Ahmedabad-380015. Pan: Ablpm2848Q (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri M K Patel, With Shri Vartik Choksi, Ars Revenue By : Shri Sher Singh, Cit.Dr

For Appellant: Shri M K Patel, with Shri Vartik Choksi, ARsFor Respondent: Shri Sher Singh, CIT.DR
Section 132Section 143(3)Section 153CSection 263

आयकर अपीलीय अिधकरण, अहमदाबाद "यायपीठ , अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “ D” BENCH, AHMEDABAD ] BEFORE SHRI SANJAY GARG, JUDICIAL

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Vivek Gupta, Kolkata

Appeal of the revenue is dismissed and cross objection is partly allowed

ITA 1592/KOL/2025[2017-18]Status: DisposedITAT Kolkata20 Jan 2026AY 2017-18

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 133ASection 143(1)Section 250Section 68

Ground No. 4. 8. The issue raised in Ground No. 5 against the deletion of disallow- ance of Rs. 61,151/- made under section 36(1)(iii) of the Act on account of interest paid on alleged bogus loans. Since we have upheld the order