CIT v. Ceebros Hotels P. Ltd. (2022) 440 ITR 200/ 284 Taxman 205 (Mad.)(HC)

S. 36(1)(iii) : Interest on borrowed capital-Borrowed money was used for the purpose of business-Expansion of business-Order of Tribunal is affirmed.

Dismissing the appeal the Court held that the observation of the Tribunal  that the purchase of inventory in the course of carrying on business should be reckoned as continuation of the same business activity in the normal course and could not be equated or termed an extension of business activity. Furthermore, the Tribunal noted that the assessee had offered substantial income from the Egmore project and the attempt to apply the matching principle concept was misconceived. The assessee was able to establish that substantial activities had been done in the project, which would go to show that the property purchased had been put to use. Order of Tribunal is affirmed. (AY.2015-16)