Indbank Merchant Banking Services Ltd. v. Dy.CIT (2022) 94 ITR 4 (SN) (Chennai)(Trib.)

S. 80M : Inter corporate dividends-Fifty Per Cent. of average cost of borrowing considered as proportionate to earning of income from dividend out of borrowed funds-Proportionate interest expenditure alone to be disallowed-No disallowance of management expenses.

Held that fifty Per Cent. of average cost of  borrowing considered as proportionate to earning of  income from dividend out of  borrowed funds, therefore proportionate interest expenditure alone to be disallowed.  No disallowance of management expenses shall be made.(AY. 1992-93)