Tribunal held that the principle of commercial expediency should apply mutatis mutandis to the year under consideration for investment carried forward to Assessment Year 2017-18 and accordingly, the Assessing Officer was directed to apply the principle of commercial expediency to said portion of investment and delete the corresponding disallowance under section 36(1)(iii). As far as other investments which were not covered in terms of commercial expediency, the issue was to be restored to the file of the Assessing Officer for limited verification of disallowance under section 36(1)(iii).(AY. 2016-17)
Kausalya Agro Farms and Developers (P.) Ltd. v. ITO (2025) 215 ITD 401 (Hyd) (Trib.)
S. 36(1)(iii): Interest on borrowed capital-Commercial expediency-Interest allowed in earlier year-The principle of commercial expediency applied mutatis mutandis to the corresponding portion, and such disallowance was not warranted.[S. 251]
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