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2011 (8) TMI 524

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..... tar, Mumbai" - held that:- The Tribunal has also held that this expenditure would be allowed even under section 57(iii) of the Act. Though there may be some controversy as to whether the aforesaid expenditure is allowable under section 57(iii) of the Act or not, we have no doubt, in our mind, that the expenditure incurred under the aforesaid circumstances would be treated as expenditure incurred f .....

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..... cer (AO) refused to allow this expenditure. However, the Commissioner of Income-tax (Appeals) reversed the decision of the Assessing Officer and the opinion of the Commissioner of Income-tax (Appeals) has been confirmed by the Income-tax Appellate Tribunal (ITAT) by the impugned orders which relate to different assessment years. Challenging the said orders, these appeals are preferred. 2. A pe .....

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..... s a deep interest in its subsidiary, and hence if the holding company advances borrowed money to a subsidiary and the same is used by the subsidiary for some business purposes, the assessee would, in our opinion, ordinarily be entitled to deduction of interest on its borrowed loans. 3. In these circumstances holding it to be expenditure incurred for business the same was allowed under section .....

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..... s aspects deal in hotels, motels, resorts, inns, guest houses, apartments, food courts, shopping plazas, commercial complexes, casinos, entertainment parks, water parks, amusement centres, gaming centres, bowling alleys, wild life parks, restaurants, cafes, refreshment rooms, lodging houses of every kind and sort including all the conveniences, amenities and facilities adjunct thereto, in India or .....

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