Notional interest disallowance u/s. 36(1)(vii) quashed as interest on borrowed fund allowable as revenue expense

Joyalukkas (India)Pvt. Ltd Vs ACIT (ITAT Cochin) ITAT Cochin held that disallowance of notional interest u/s. 36(1)(viii) of the Income tax Act set aside since borrowed funds were used for renovation of leasehold premises and the same is allowed as revenue expense and hence interest on such borrowing is allowed as revenue expense. Facts- The appellant is engaged in the business of manufacturing and trading gold ornaments, textiles, life style products etc. TPO rejecting the TP study submitted by the appellant and proceeded with the benchmarking the international transaction by rejecting the in...