ACIT v. HDFC Bank Ltd.(2020) 82 ITR 533 (Mum.)(Trib.)

S. 37(1) : Business expenditure-Bank-Broken period interest-Paid for securities at time of acquisition-Allowable as deduction-Appellate Tribunal-Pronouncement of 90 days-Lockdown period to be excluded [ITAT R.34(5)]

The assessee debited an amount of Rs. 1,947 crores in the profit and loss account as broken period interest on the ground that this broken period interest paid was part of the price paid for the securities at the time of its acquisition. The Assessing Officer observed that the purchase price was in the nature of capital outlay and could not be allowed as deduction while computing business income of the assessee. The Commissioner (Appeals) deleted the addition the Tribunal held that   the broken period interest paid by the assessee was allowable as deduction while computing the total income of the assessee..(AY. 20011-12)