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2023 (3) TMI 196 - ITAT MUMBAIInterest expenses capitalised to WIP - Reducing the work in progress (WIP) on account of proportionate disallowance of interest expenses capitalised to WIP mainly incurred on account of secured loans - HELD THAT:- Undisputedly assessee has taken loan of Rs.411.9 crore against which claimed interest expenses of Rs.59.91 crore but at the same time the assessee has also given loans and advances amounting to Rs.208.52 crores to various parties. AO allowed the interest at the rate of 14.5% on the basis of ledger of the assessee. When the assessee has failed to prove the nexus of interest free funds with advances made rather advanced the loan out of common pool and no other facts have been brought on record before the Tribunal we do not find any illegality or perversity in the impugned findings given by the CIT(A). The assessee despite availing numerous opportunities has failed to appear before the Tribunal to assist the Bench to unsettle the findings returned by the CIT(A). Income from house property - Treating the business centre income generated from providing business facilities as income taxable under the head “income from house property” - HELD THAT:- There is nothing on record if the findings returned in the earlier years have been disturbed. The assessee has not come up before the Tribunal to explain as to how the said income is to be treated as business income. So we find no illegality or perversity in the impugned addition confirmed by the CIT(A). In view of what has been discussed above present appeal filed by the assessee is hereby dismissed.
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