PCIT v. Mahalaxmi Design Pvt. Ltd (2025) 482 ITR 215 / 174 taxmann.com 149 (Delhi)(HC)

S. 57 : Income from other sources-Deductions-Expenditure for purposes of earning-Borrowing money and lending it to others-Interest on borrowed money-Allowable as deduction.[S.56, 57(iii)]

Dismissing the appeal of the revenue the Court held that there was a direct nexus between the money borrowed by the assessee and money advanced by the assessee. The assessee paid interest on the money borrowed by it and had received the interest on the money advanced by it. The interest paid by the assessee was incurred wholly and exclusively for the purpose of earning of interest income. Order of Tribunal allowing the deduction, is affirmed. (AY. 2010-11)

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