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2015 (2) TMI 1203 - AT - Income TaxRevision u/s 263 - CIT took the view that the interest on loans relatable to dividend so declared is not allowable as deduction under Section 36(1)(iii) - Held that:- As already noticed that the Ld. CIT has passed the impugned revision order only on the reasoning that the interest on borrowings, if any made, for disbursing dividend is not allowable as deduction under Section 36(1)(iii) of the Act. However, the various case laws relied on by the Ld. counsel make it very clear that the interest on the amounts borrowed for payment of dividend is allowable as deduction. Thus, it is seen that the very foundation on which the impugned revision order has been passed by Ld. CIT fails, in which case we are not able to sustain the same. Accordingly, we set aside the revision order passed by the Ld. CIT. - Decided in favour of assessee
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