Ao allowed interest on Loan on wrong assumption of facts: Exercise of section 263 Jurisdiction Valid 

Michelle Y. Poonawalla Vs PCIT (ITAT Pune) Admittedly, the assessee availed loan from Reliance Home Finance Limited for Rs.8,68,50,000/- and paid interest thereon @ 12.50%. Admittedly, the said borrowed loan was paid to statutory tenants in pursuance of relinquishing deed dated 05-04-2011. The PCIT held the interest paid on such borrowed amount does not fit into provisions of clause (b) of section 24 of the Act. The PCIT reproduced the said provisions in the impugned order at Para No. 6. On plain reading the said clause (b) of section 24 of the Act explains that the deduction is allowable wher...