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2013 (4) TMI 262 - AT - Income Tax
Disallowance of entire interest expenditure claimed in the Profit & Loss Account - assessee company is in the business of financing and investment - Held that:- As from the balance sheet of the assessee, it is evident that the total loans and advances are only Rs.8,212/-. The sundry debtors is also only Rs.1,38,574/-. As already stated that the onus is upon the assessee to establish that the money was borrowed for the purpose of business. The assessee has not established how the huge sum of Rs.34 crores was utilized for the purpose of business because the total investment in business of trading in shares/financing is in lakhs. The total investment in shares, sundry debtors, cash and bank balance and loans and advances taken together is only Rs.2,65,323/-.
Thus agreeing with the finding of the lower authorities that the assessee has not been able to discharge the onus which lay upon it to establish that the borrowed money has been utilized for the purpose of business. The various decisions relied upon by the assessee are altogether different on facts - against assessee.