Summary
- The ITAT Mumbai has allowed Harsh Estates Pvt. Ltd. to claim interest deductions for AYs 2013-14, 2014-15, and 2015-16, following precedents set in earlier group cases.
- The Tribunal's decision was based on the nexus between historical borrowings and income-generating bank deposits, despite the absence of formal agreements.
- It directed the Assessing Officer to recompute statutory interest under Sections 234A, 234B, and 234C while dismissing all Revenue appeals related to capitalisation of interest.
- This ruling reinforces the importance of consistent treatment in tax matters and could influence future assessments involving similar entities.
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