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Nsl Sugars Limited ,Bengaluru vs Dcit, Central Circle-3(2), Bengaluru on 8 January, 2026

22.3 Reliance was placed on judicial precedents, including the decision of the Hon'ble Karnataka High Court in ACE Designers Ltd. v. ACIT, wherein it was held that loss arising from investment in a wholly owned subsidiary made for business purposes is allowable as a business loss. The assessee contended that the ratio of the said decision squarely applies to the present case, and the mere fact that the amount was routed as a loan instead of equity does not change the nature of the loss. The Assessing Officer, according to the assessee, erred in treating the loss as capital in nature and in rejecting the claim only on the IT(TP)A No.2615/Bang/2024 Page 15 of 30 ground that the facts were different. In view of the above facts and legal position, the assessee prayed that the write-off of the loan given to the wholly owned subsidiary be allowed as a business expenditure under section 37 of the Act. However, the learned DRP rejected the assessee's objection by observing as under:
Income Tax Appellate Tribunal - Bangalore Cites 20 - Cited by 0 - Full Document
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