Assessee-company acquired machinery out of loan availed from bank. Till end of relevant year, machine was not put to use. Assessee claimed deduction on account of interest paid on said loan. AO disallowed deduction by holding that interest expense could not be allowed as deduction until the machinery was put to use. Tribunal held that since value of machine acquired was negligible to value of plant and machinery as shown in assessee’s balance sheet of subject year, such small addition in plant and machinery could not amount to extension of existing business, and, thus, interest expense incurred by assessee was eligible for deduction. (AY. 2011-12)
K. B. Mehta Construction (P.) Ltd. v. DCIT (2020) 185 ITD 81 (Ahd.)(Trib.)
S. 36(1)(iii) : Interest on borrowed capital-Purchase of machinery-Interest is allowable as deduction even if said machinery was not put to use in year under consideration.