Sharp Business System (Through Finance Director Mr. Yoshihisa Mizuno) v. CIT (2026) 484 ITR 509/308 Taxman 285 /348 CTR 1 / 257 DTR 49 (SC) Editorial : Sharp Business System v. CIT (2026) 484 ITR 496 (Delhi) (HC)

S. 36(1)(iii): Interest on borrowed capital-Advance to subsidiary-investment made for acquiring controlling interest in associate concern-Commercial expediency-Allowable as deduction.

Held that the assessee had claimed interest on borrowed funds under section 36(1)(iii) of the Act, which were utilised for investment in a subsidiary company of the assessee. The investment was made to control the interest in the associate concern by the purchase of shares. Thus, the investment was clearly for commercial expediency. The finding recorded by the Tribunal and affirmed by the High Court that the assessee was entitled to claim allowance of interest on the funds invested in the sister concern for acquiring the controlling interest was correct.  That the purpose for which the advances were made to the sister concern and its directors was also covered by the principle of commercial expediency. (AY. 2001-02, 2002-03)

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