Interest exp. not deductible if shares acquired from borrowed fund were used for making long-term investments

Where assessee-company was not engaged in carrying on any business activity of acquisition of shares except making long-term investments, activity carried out by assessee was investment activity and accordingly expenditure incurred under head finance charges not incurred wholly and exclusively for purpose of business was not allowable under section 36(1)(iii)

Where dividend income earned by assessee was taxable under head 'Income from other sources', any expenditure incurred to earn dividend income including finance charges was to be allowable under section 57(iii)

Where once addition on which penalty has been levied is set aside to Assessing Officer for fresh consideration, it is as good as there is no addition for levy of penalty under section 271(1)(c)

Refer:[2018] 91 taxmann.com 431 (Mumbai - Trib.)