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Unabsorbed interest on borrowings(floating rate notes - FRN's) taken for infructuous/abandoned capital projects - whether an allowable expenditure? 

Facts:

Assessee had raised FRN for various projects. Part of the interest on these loans were added to the cost of capital projects/cwip/assets. On abandoned projects the interest was claimed as an expenditure. This was disallowed by lower authorities. On higher appeal -

Held in favour of the assessee that interest on borrowings(floating rate notes - FRN's) taken for infructuous/abandoned capital projects - were an allowable expenditure. 

Applied:

B. Nagi Reddy vs. CIT (1993) 199 ITR 451 (Mad-HC) : 1993 TaxPub(DT) 0184 (Mad-HC)

Chemplast Sanmar vs. ACIT [TCA No. 859 of 2008, dt. 07-08-2018] : 2018 TaxPub(DT) 5613 (Mad-HC) 

Dissented: 

Eid Parry (India) Ltd. (2002) 257 ITR 253 (Mad-HC) : 2002 TaxPub(DT) 0883 (Mad-HC)

Case: Southern Petrochemical Industries Corpn. Ltd. v. ITO 2024 TaxPub(DT) 247 (Chny-Trib)

 

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