Whether the interest on borrowed funds used for setting up a new unit before the asset was put to use should be capitalized u/s 36(1)(iii) or allowed as revenue expenditure ????
The assessee has treated the interest paid on borrowed capital for the establishment of new unit at baddi as revenue expenditure. Where as department has the view that capital borrowed for the purpose of establishing new plant should be capitalised instead of revenue. As per section 36(1)(iii) and relying upon the judgement of the DCIT vs. Core health Pvt. Ltd. Tribunal decided the appeal in favour of the assessee. The hon’ble Punjab & Haryana High Court relying upon the judgment of Hon’ble Supreme Court of India, in Civil Appeal No.6438 of 2012 titled ‘M/s Vardhman Polytex Limited, Ludhiana Vs. Commissioner of Income Tax‘ held the same to be treared as Revenue expenditure.
