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Income Tax - Highlights / Catch Notes

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Disallowance of interest on inter-corporate deposits - The ...


Interest Disallowance on Inter-Corporate Deposits Challenged; No Nexus Found Between Borrowed Funds and Deposits.

January 11, 2024

Case Laws     Income Tax     AT

Disallowance of interest on inter-corporate deposits - The observation of Ld. AO that there was increase in borrowed funds during AY 2003-04 has no relevance since the ICDs were placed by the assessee during financial year 1999- 2000 and it was impossible to make investment in 1999-2000 out of funds borrowed in subsequent years. Further, the nexus of borrowed funds with the ICDs have not been established by Ld. AO. - AT

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