Dismissing the appeal of the revenue the Court held that interest expenditure and finance expenditure incurred on loans taken for investment in acquiring controlling interest in a foreign subsidiary which is n same line of business of assessee so as to expand the business in foreign country is held to be allowable expenditure. Followed CIT v Srishti securities (P) Ltd. (2010) 321 ITR 498 (Bom.)(HC) (AYs. 2008-09, 2009-10)
PCIT v. Concentrix Services (I) (P.) Ltd. (2019) 267 Taxman 625 (Bom.)(HC)
S. 36(1)(iii) : Interest on borrowed capital–Interest and finance charges-loans taken for investment in acquiring controlling interest in a foreign subsidiary which is in same line of business-Allowable as expenditure. [S. 37(1)]