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2024 (3) TMI 1067 - ITAT VISAKHAPATNAMDeduction of interest expenditure incurred on borrowed funds u/s 57 - Interest incurred on borrowed funds utilized for making investment in shares in company of Singapore - expenditure allowable u/s. 57 or not? - HELD THAT:- As not disputed that the assessee’s investment in M/s. Dolphin Overseas Private Limited, Singapore is for the purpose of earning income in the future periods. Revenue Authorities also did not bring on record that the investment was made by the assessee otherwise than for the purpose of making an income. We observed that section 57(iii) is clear and has to be construed according to its natural meaning. It should not be given a narrowed meaning and the interpretation of section 57(iii) cannot be held to be conditional upon making or earning of the income. As relying on SRI SAYTASAI PROPERTIES & INVESTMENT PVT. LTD. case [2014 (2) TMI 796 - CALCUTTA HIGH COURT] we are of the considered view that the assessee is eligible to claim deduction of interest expenditure incurred on borrowed funds utilized for making investment in shares of M/s. Dolphin Overseas Private Limited, Singapore as per the provisions of u/s. 57 of the Act. Appeal filed by the assessee is allowed.
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