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2022 (9) TMI 1248 - AT - Income TaxDisallowance of interest on estimated basis (50% of the total interest claimed in the profit on loss account) - interes disallowed on the ground that assessee has sufficient fund still the assessee has obtained loan - HELD THAT:- CIT (A) is trying to enter in the shoes of a businessman and decide when the businessman should take loan and when he should not take loan and use his own funds. It is settled law that such an exercise by the Revenue is not at all sustainable if the assessee has sufficient funds and it has not been diverted for activities which could not earn interest, disallowance cannot be made on the ground of prudence which should have been done in the opinion of the Revenue authorities. Hence, we are of the considered opinion that the order of ld. CIT (A) is not sustainable and accordingly we set aside the same on this issue. Funeral expenses - Assessee’s claim was that the same was related for business inasmuch as expenditure represents payment mad to microfinance clients on the death of their family members. It was held by the Revenue authorities to be not related to the business of the assessee. In our considered opinion on the facts and circumstances of the case, this expenditure deserves to be allowed and same is directed to be allowed accordingly. Appeal of assessee allowed.
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