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Loan Processing Fees on LAP/LRD Loans Not Deductible Under Section 24(b)
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ITATtax

Loan Processing Fees on LAP/LRD Loans Not Deductible Under Section 24(b)

May 19, 2026

The ITAT upheld the disallowance of loan processing fees for loans not securing property for generating rental income, reiterating limitations on Section 24(b) deductions. This ruling clarifies acceptable expenses under the section.

ITAT Rules on Deductibility of Loan Processing Fees

The Income Tax Appellate Tribunal (ITAT) has upheld the disallowance of ₹11.71 lakh in loan processing fees, identifying these loans as being obtained for broader business purposes rather than specific acquisitions that would entitle a deduction under Section 24(b). The ruling emphasizes the necessity of precision in aligning loan purposes with deductible expenditures.

The ITAT clarified that Section 24(b) limits deductions only to those expenses that directly relate to earning rental income, thus narrowing the scope of eligible deductions for businesses involving loans for diverse financial purposes.

This ruling provides significant guidance for tax practitioners, highlighting the need for detailed documentation and justifying loan expenses in relation to rental income generation to claim deductions efficiently under Section 24(b).

Citations

  • ITAT Case No. 1749/2026
Source:ITAT
Practice Areas:tax