Top Stories Rulings on Disallowance of Interest under Income Tax Act This Case Digest provides an analytical summary of judgments and observations related to the disallowance of interest under Income Tax act, reported in Taxscan.in By Franklin Joshva – On February 3, 2025 3:44 pm – 14 mins read Disallowance of Interest means any interest which is disallowed for non-compliance with the provisions of the Income Tax Act, 1961. The Income Tax Act, 1961, states about restrictions for claiming interest deductions in cases to prevent tax avoidance, ensure proper tax compliance, and maintain the integrity of tax deductions. Section 2 (28A) defines interest payable in any manner in respect of any moneys borrowed or debt incurred including a deposit, claim or other similar right or obligation and includes any service fee or other charge in respect of the moneys borrowed or debt incurred or in respect of any credit facility which has not been utilised. The Income Tax Act gives about Disallowance of interest in various provisions of the Act. Section 36(1)(iii) Section 36(1)(iii) allows deduction for interest on capital borrowed for the purpose of business or profession.

“Section 36(1)(iii)- the amount of the interest paid in respect of capital borrowed for the purposes of the business or profession” However, the claim of interest deduction will be disallowed on certain circumstances : If the borrowed capital is used for other than business or profession purposes, the claim of deduction will be disallowed. If the borrowed capital is used for the acquiring asset, then the interest will be used. Section 40(a) and 40(ia)   Section 40(a) states that the amount of interest paid without deducting Tax Deduction at Source (TDS) as per section 194A, then the interest will be disallowed. Section 40(ia) states that thirty percent of any sum of amount payable to the resident, for which TDS is not deducted then the interest will be disallowed.  Section 43B (d),(da) and (e) Section 43B(d),(da) and (e) states that any sum payable by the assessee of an interest on any loan or borrowing is allowed for deduction if it borrowed from, public financial institution, non-banking financial company, from a scheduled bank However, if the interest is actually not paid before the due date of filing Income Tax Return( ITR ) u/s 139(1) then Interest  is disallowed for that assessment year. Section 40 (b)(iv) Section 40 (b)(iv) states that the interest payable to the partner by virtue of the partnership deed exceeds twelve percent then interest can be disallowed. “ Section 40(b)(iv)-any payment of interest to any partner which is authorised by, and is in accordance with, the terms of the partnership deed and relates to any period falling after the date of such partnership deed in so far as such amount exceeds the amount calculated at the rate of twelve percent simple interest per annum “ Section 94b Section 94b states that expenditure incurred by Indian companies and permanent establishment of a foreign company in India by way of interest then the interest deduction is restricted to 30%.  The excess interest exceeding 30% can be disallowed but it can be carried forward for 8 years.  S. 263 Order passed by PCIT by Violating Principles of Natural Justice:

ITAT quashes Disallowance of Interest on Grant of Rs. 4.18 crore Gujarat Power Corporation Ltd. vs Principal Commissioner of Income Tax CITATION: 2024 TAXSCAN (ITAT) 1636. The Ahmedabad bench of the Income Tax Appellate Tribunal ( ITAT ) held that the order passed under Section 263 of the Income Tax Act, 1961, was passed by the Principal Commissioner of Income Tax ( PCIT ) by violating the principles of natural justice and quashes disallowance of interest on a grant of Rs. 4.18 crore. The PCIT noted that the AO failed to verify the allowability of interest on grants claimed as revenue expenditure. Therefore the PCIT set aside the assessment order, terming it erroneous and prejudicial to the Revenue’s interest. The assessee has appealed against the order. Interest not Leviable from Assessee for Short Payment of Tax due to Payer’s Default in TDS Deduction: ITAT Computer Modelling Group Ltd vs ACIT, Circle International Taxation CITATION: 2024 TAXSCAN (ITAT) 623 The Delhi Bench of Income Tax Appellate Tribunal (ITAT) has held that interest is not leviable from the assessee for the short payment of tax due to payer’s default in Tax Deduct at Source (TDS). The tribunal held that the proviso to Section 209(1) issued by the Finance Act, 2012, was applicable prospectively after FY 2012–13; there was no liability for the assessee to pay interest under Section 234B of the Act for the impugned AYs since the entire income was tax deductible at source in the hands of the payer. No Disallowance of Interest Expenditure not claimed during Deposit of Tax in Return: ITAT directs re-adjudication WLD Investments Pvt. Ltd vs DCIT CITATION: 2024 TAXSCAN (ITAT) 327

The Delhi bench of Income Tax Appellate Tribunal (ITAT) while directing readjudication observed that no interest expenditure should be disallowed which has not been claimed during the deposit of tax in return. WLD Investments Pvt. Ltd. (assessee) e-filed return of income belatedly under Section 139(4) of the Act showing ‘Nil’ income. The AO disallowed the 30% of the interest payments of Rs.14,53,08,907/- and a disallowance of Rs.4,35,92,672/-was carried out by the AO without appreciating the facts in prospective. The tribunal remit the matter back to the AO for determining the issue afresh on the basis of relevant facts that may be placed by the assessee before the AO. Disallowance of ₹16.84 Lakhs as LC Discounting Charges u/s 36(1)(iii): ITAT Finds Addition Unjustified BPS Mineral Exports Pvt. Ltd. vs Income Tax Officer CITATION: 2025 TAXSCAN (ITAT) 261 BPS Mineral Exports Pvt. Ltd.,appellant-assessee,engaged in trading various products, filed its return on October 29, 2017, declaring a loss of Rs. 2,14,691/-. The assessment was finalized at Rs. 15,47,014/- after adding Rs. 17,61,705/- for disallowance under Section 36(1)(iii) due to interest-bearing funds allegedly used for interest-free loans. The Ahmedabad Bench of Income Tax Appellate Tribunal ( ITAT ) found the addition of ₹16.84 Lakhs as LC discounting charges under Section 36(1)(iii) of Income Tax Act,1961 to be unjustified. ITAT quashes Disallowance u/s 36(1)(iii) of Income Tax Act on Interest-Free Advances given to Sister Concern of Assessee Deccan Charters Pvt. Ltd vs DCIT CITATION: 2024 TAXSCAN (ITAT) 1367 Deccan Charters Pvt. Ltd., (assessee) is a company in the aviation services business based in Bengaluru and filed its Income Tax Returns for the assessment year ( AY ), declaring a total loss of Rs. 10,93,70,970.

The AO noted that the assessee had given interest-free advances to related concerns while paying interest on borrowed loans and disallowed Rs. 2.56 crore under Section 36(1)(iii) of the Income Tax Act. The Bangalore Bench of the Income Tax Appellate Tribunal ( ITAT ), found merit in the assessee’s contention that no new advance was extended to the sister concern. Therefore, the tribunal quashed the disallowance under Section 36(1)(iii) of the Income Tax Act, 1961, on interest-free advances provided to the assessee’s sister concern. ITAT Deletes Interest Disallowance u/s 36(1)(iii) for Genuine Unsecured Loans, Upholding CIT(A) Decision Ardor Overseas Pvt. Ltd. vs The DCIT CITATION: 2024 TAXSCAN (ITAT) 1281 Ardor Overseas Pvt. Ltd., the appellant-assessee, was involved in a land transaction with Nikshal Properties Pvt. Ltd., who sold the land to the assessee for Rs. 44 crores, though it had originally purchased the land for Rs. 8 crores just a few days prior.

The AO added Rs. 8 crores to the assessee’s income under Section 68 of the Act, and the AO also disallowed interest paid on the loan, part of which had been capitalized as the cost of land. The The Ahmedabad Bench of Income Tax Appellate Tribunal ( ITAT ) deleted the disallowance of interest under Section 36(1)(iii) of the Act, affirming that the interest paid on the unsecured loans was deductible and consistent with previous assessments regarding the genuine nature of the transactions. ITAT deletes Disallowance of Rs.26.25 Lakh u/s 36(1)(iii) based on Records of Sufficient Interest-Free Funds and Commercial Expediency Oriental Enterprise Pvt.Ltd vs The ACIT Circle CITATION: 2024 TAXSCAN (ITAT) 1069 Oriental Enterprise Pvt. Ltd., (assessee) gave a loan of Rs.1.75 crore to its subsidiary, Oriental Nicco Projects Pvt. Ltd., at an interest rate of 15% but the assessee did not show interest income in the financial statements for the assessment year 2016-17. The assessing officer scrutinized the loan given to its subsidiary during the assessment proceedings. The AO questioned the interest-free nature of the loan when the assessee-company itself had interest expense during the same period. Therefore, the AO disallowed a proportionate amount of ₹26.25 lakh under Section 36(1)(iii) of the Income Tax Act, reasoning that the borrowed funds were not used exclusively for business purposes.

The Ahmedabad Bench of the Income Tax Appellate Tribunal ( ITAT ) deleted the disallowance of Rs. 26.25 Lakh under Section 36(1)(iii) of Income Tax Act, 1961. This decision was made based on the assessee’s records submission of sufficient interest-free funds and commercial expediency. Disallowance for Non-Deduction of TDS on Reimbursements: ITAT Rules It Unjustified Due to Tax Compliance CRISIL LIMITED vs The Assistant Commissioner CITATION: 2025 TAXSCAN (ITAT) 304 Crisil Limited, appellant-assessee, had been assessed under section 143(3) with an addition of Rs. 1,07,51,004/- under section 40(a)(ia) for non-deduction of tax on reimbursements. The assessee succeeded in the first appeal before the Commissioner of Income Tax (Appeals)[CIT(A)] had deleted the disallowance. However the revenue appealed before the tribunal and the matter was restored for verification. The Assessing Officer (AO) had confirmed the disallowance of Rs. 74,57,621/- but deleted the disallowance of Rs. 32,93,383/-, which was for reimbursement of expenses where no TDS applied, as directed by the tribunal. The CIT (A) increased disallowance of Rs. 32,93,383/-. The Mumbai Bench of Income Tax Appellate Tribunal (ITAT) ruled that the disallowance of ₹1.07 Crore for non-deduction of Tax Deducted at Source (TDS) on reimbursements under Section 40(a)(ia) of Income Tax Act,1961 was unjustified due to tax compliance. Disallowance u/s 40(a)(I) of the Income Tax Act is not Applicable as per DTAA between India and Japan: Delhi HC rules in Favour of Mitsubishi Corp India THE COMMISSIONER OF INCOME TAX-II vs MITSUBISHI CORPORATION INDIA P. LTD. CITATION: 2024 TAXSCAN (HC) 524 The appellant/revenue challenged the order passed by the Income Tax Appellate Tribunal which was ruled in Favour of Mitsubishi Corp India, the assessee.

The question was whether the ITAT fell into error in holding that Section 40(a)(i) of the Income Tax Act, 1961 cannot be applied in view of the provisions of the Double Tax Avoidance Agreement between the Indian (sic) and Japan and India and the US. The Court observed that it was not obliged to deduct TAS from payments made to MC Metal (Thailand) and Metal One (Singapore). Chargeability to tax is the paramount condition for triggering the obligation to deduct TAS. The plain language of sub-section (1) of Section 195 brings this aspect of the matter to the fore. Therefore, the Delhi High Court held that disallowance under section 40(a)(i) of the Income Tax Act, 1961 is not applicable in view of the provision of Double Taxation Avoidance Agreements (DTAAs) entered into by India with Japan and the USA. Voluntary Disallowance of Expense u/s 40 (a) (ia) not a base to treat Taxpayer as ‘Assessee in Default’: ITAT ACIT (TDS) vs Artemis Medicare Services Ltd CITATION: 2024 TAXSCAN (ITAT) 251 The assessee company in the revised computation of income filed before the ld. AO along with the revised return filed, which is well within the time limit prescribed u/s 139(5) of the Act, had disallowed voluntarily a sum of Rs 2,53,57,043/- on the year-end provision of expenses u/s 40(a)(ia) of the Act. The said expenses were disallowed u/s 40(a)(ia) of the Act in the revised return on the ground that the said expenditures were not subjected to deduction of tax at source. The AO held that the assessee itself had voluntarily disallowed the same u/s 40(a)(ia) of the Act in the return of income and accordingly needed to be treated as “assessee in default” under section 201(1) and consequential interest under section 201(1A) of the Act. The Delhi bench of the Income Tax Appellate Tribunal (ITAT) has held that voluntary disallowance of an expense under section 40 (a) (ia) of the Income Tax Act, 1962 is not a basis to treat a taxpayer as ‘assessee in default’. Section 40(a)(ia) of Income Tax Act is Declaratory and Retrospective: Delhi HC PRINCIPAL COMMISSIONER OF INCOME TAX -7 vs M/S SHIVAAI INDUSTRIES PVT. LTD CITATION: 2023 TAXSCAN (HC) 1803 The record revealed that the AO for the AY 2008-09, had made an addition amounting to Rs.17,67,16,747/- under Section 40(a)(ia) of the Act via the assessment order. The amount that was added to the income of the respondent/assessee, i.e., Rs.17,67,16,747/-, were site rent payments made to the Delhi Transport Corporation (DTC) concerning advertisement space made available on bus shelters and timekeeper booths.

The respondent/assessee had succeeded in earlier years as, on the addition, made in a similar circumstance, was deleted by the Tribunal. The Court observed previous decisions of the Supreme Court, it was held that “the insertion of second proviso to Section 40(a)(ia) is declaratory and curative in nature and it has retrospective effect from 1st April 2005, being the date from which sub-clause (ia) of section 40(a) was inserted by the Finance (No.2) Act, 2004.”  The Delhi High Court held that Section 40(a)(ia) of the Income Tax Act, 1961 is declaratory and retrospective and closed the petition in the absence of substantial question of law. Sale Agents rendered Services outside India and Payment made directly through Foreign Exchange are not Taxable under India-USA DTAA: ITAT allows Disallowance u/s 40(a)(i) Sunbeam Lightweighting Solutions Pvt. Ltd. vs ACIT CITATION: 2023 TAXSCAN (ITAT) 2611 The assessee is engaged in the business of manufacturing automotive die-cast components, I.C. Engine parts, and pistons for two-wheelers and four-wheelers since inception. The Assessing Officer found that services rendered by these parties are not merely for the sale of products of the assessee company but for prospecting, marketing, and providing comprehensive and integrated services.   The Assessing Officer had made the disallowance considering services to be Fees for Technical Services (FTS) and the disallowance under Section 40(a)(i) of the Income Tax Act was made.

The Delhi bench of the Income Tax Appellate Tribunal (ITAT) allowed the disallowance under Section 40(a)(i) of the Income Tax Act, 1961, and held that the sale agents rendered services outside India and payment made directly or wholly through foreign exchange are not taxable under India-USA Double Taxation Avoidance Agreement (DTAA). Provisions of S.40(a)(ia) not Applicable for Non-Deduction of TDS in Salary prior to AY 2015-2016: ITAT Deletes Disallowance (Erstwhile) Sumaitri Bima Distributors Pvt. Ltd vs Income Tax Officer CITATION: 2023 TAXSCAN (ITAT) 2461 The assessee,(Erstwhile) Sumaitri Bima Distributors Pvt. Ltd was a general insurance commission agent and had earned commission income from general insurance business.    This payment was made without deduction of tax at source by the assessee. The assessee was of the bonafide belief that since the employees were on the rolls of Escorts Finance Ltd, the salaries were paid by the Escorts to the employees The salaries were subjected to deduction of tax at source in terms of Section 192 of the Income Tax Act by Escorts and since the assessee had merely reimbursed the salary, there was no obligation on the part of the assessee to deduct tax at source. The Delhi Bench of Income Tax Appellate Tribunal (ITAT) has deleted the disallowance holding that the provisions of Section 40(a)(ai) of the Income Tax Act 1961 was not applicable for non-deduction of Tax Deducted at Source (TDS) in salary prior to annual year 2015-2016. Disallowance made by AO u/s 40(a)(ia) for non-deduction of TDS and recovery of rent from assessee by holding company are not sustainable:

ITAT MCNALLY BHARAT INFRASTRUCTURE LIMITED vs DCIT CITATION: 2023 TAXSCAN (ITAT) 2259 The AO had observed that the assessee has claimed expenses on rent at Rs. 15,98,400/-. However, the assessee has not deducted TDS as required under section 40(a)(ia) of Income Tax Act. Therefore, the AO had disallowed expenses of Rs. 15,98,400/- in the hands of assessee. The tribunal observed that the actual payments are made by the lessee (holding company) to the lessor and necessary tax was deducted there from. The holding company has only debited the rent which pertains to the part of the premises occupied by assessee. Therefore, The Kolkata bench of the Income Tax Appellate Tribunal (ITAT) held that Disallowance made by AO under Section 40(a)(ia) of the Income Tax Act for non-deduction of TDS under section 194I cannot be sustained for the holding company only debited the rent part of the premise occupied by the assessee. Disallowance u/s 40(a)(ia) of Income Tax Act shall be imposed when Assessee fails to deduct TDS on amount of Interest to NBFCs: ITAT Sanjay Bajpai Builders Private Limited vs Assistant Commissioner of Income Tax CITATION: 2023 TAXSCAN (ITAT) 2069 The assessee company had failed to deduct tax at source under Section 194A of the Income Tax Act on the amount of interest of Rs.52.97 lacs that was paid to the aforementioned NBFCs.

The claim of the assessee was the respective payee companies had included the aforementioned amounts of interest in their respective returns of income for the year under consideration. The Raipur bench of the Income Tax Appellate Tribunal (ITAT) held that the disallowance under Section 40(a)(ia) of the Income Tax Act, 1961 shall be imposed when the assessee failed to deduct the Tax Deducted at Source (TDS) on the amount of interest to Non-Banking Financial Company (NBFC). No Disallowance u/s. 40(a)(ia) of Income Tax Act can be Made for Short Deduction of Tax: ITAT DCIT vs M/s. Shiv Build India CITATION: 2023 TAXSCAN (ITAT) 1659 Shiv Build India, the respondent-assessee filed a return of income and the assessing officer made disallowance under section 40(a)(ia). Later the Commissioner of Income Tax (Appeals) deleted the disallowance made by the assessing officer. Therefore, the revenue appealed against the order of the commissioner. The assessee submitted that  surcharge was not deducted on TDS deducted on payments as provided in section 194C of the Income Tax Act. Therefore, the Ahmedabad bench of the Income Tax Appellate Tribunal (ITAT) after hearing both sides held that no disallowance was made under section 40(a)(ia) of the Income Tax Act,1961 for short deductions of tax by the assessee. Disallowance made u/s 40(a)(ia) of Income Tax Act due to Non Disclosure of Amortization Expenditure on Books of Accounts: ITAT Directs Re-adjudication ACIT vs M/s. AVR Swarnamahal Jewellery Pvt. Ltd CITATION: 2023 TAXSCAN (ITAT) 1528 AVR Swarnamahal Jewellery Pvt. Ltd, the respondent-assessee claimed expenditure of some amount as ‘Amortization of discount on debentures’. The assessing officer disallowed the claim under section 40(a(a) of the Income Tax Act and the Commissioner of Income Tax (Appeals) deleted the disallowance made by the assessing officer. Therefore, the revenue appealed against the order. The Chennai bench of the Income Tax Appellate Tribunal (ITAT) directed the assessing officer to re-adjudicate the disallowance made under section 40(a)(a) of the Income Tax Act,1961 due to nondisclosure of amortization expenditures on books of account. The appeal of the revenue was dismissed by the tribunal. Claim of Deduction u/s 40(a)(ia) of Income Tax Act rejected on ground of Non Deduction of TDS: ITAT Dismisses Appeal of Assessee Shri G. Krishnamurthy vs The DCIT CITATION: 2023 TAXSCAN (ITAT) 1376 G. Krishnamurthy, the appellant assessee appealed against the order passed by the Commissioner of Income Tax (Appeals) for confirming the order passed by the assessing officer. Previously, the assessing officer disallowed the claim of deduction of expenses by invoking the provisions of section 40(a)(ia) of the Income Tax Act, 1961 for non-deduction of TDS on various items.

The Chennai bench of the Income Tax Appellate Tribunal ( ITAT) observed that the assessee could not file any evidence in support of the claim made that the other parties regarding the interest paid, publicity charges, and professional charges were included by the respective recipients in their returns of income and was unable to accept the claim made by the assessee. Therefore, the tribunal dismissed the appeal filed by the assessee for rejecting the claim of deduction under section 40)a)(ia) of the Income Tax Act,1961 on the ground of non deduction of Tax deducted at source (TDS)

. Deduction shall not be Disallowed u/s 40(a)(ia) of Income Tax Act on ground of TDS not Deducted, if Recipient includes Income from Receipts of Assessee: ITAT Ravi Lochan Singh vs Income Tax Officer CITATION: 2023 TAXSCAN (ITAT) 1356 The assessing officer found that the assessee made payment to his nine agents and claimed under the head of commission. This payment has been disallowed to on the ground that the assessee failed to deduct the TDS under Section 194H of the Income Tax Act, 1961.  The assessee submitted that the recipient has included the receipts from an assessee in its income, then in the hands of the payer, the deduction would not be disallowed under Section 40(a)(ia) on the ground that TDS was not deducted. Therefore, the Kolkata bench of Income Tax Appellate Tribunal (ITAT) accepted the contention and held that deduction should not be disallowed under Section 40(a)(ia) of Income Tax Act, 1961 on ground of Tax Deduction at Source (TDS) not deducted, if recipient include income from receipts of assessee. Disallowance of Expenditure u/s 40(a)(ia) of Income Tax Act for Non-Deduction of TDS restricted to 30% Considering Curative Nature of Amendment to Finance Act: ITAT Shri Niteshkumar Maganbhai Patel vs The ITO CITATION: 2023 TAXSCAN (ITAT) 1318 The Assessing Officer had observed that the assessee made a payment of Rs. 7,55,750/- to Sri Kanubhai M Parjapati for the work of landfilling and levelling which was like work contract and hence the same shall be liable to TDS under section 194C of the Income Tax Act. However, the assessee failed to deduct tax at source.

Hence, AO invoked the provision of section 40(a)(ia) of the Income Tax Act and disallowed the expenses. The assessee submitted that the recipient of money Shri Kanubhai Prajapati is assessed to Income Tax and the amount of landfilling and levelling charges paid to him are duly shown as income by him and paid Tax thereon and therefore Section l94C of the Income Tax Act, 1961 does not apply.  The Tribunal has held that the disallowance of expenditure under Section 40(a)(ia) of the Income Tax Act, 1961 for the non-deduction of Tax Deducted at Source (TDS) shall be restricted to 30% of the expenditure considering the curative nature of Amendment to the Finance Act. Warehouse Charges Paid Without Deducting TDS shall be disallowed u/s 40(a)(ia) of Income Tax Act: ITAT Vandana Dinehkumar Inani vs The Income Tax Officer CITATION: 2023 TAXSCAN (ITAT) 723 Vandana Dinehkumar Inani, (assessee) is a Commission Agent and General Merchant. The assessing officer held that the assessee has made payments to certain warehouses without deducting TDS. Therefore the assessing officer disallowed Rs.69,27,693/- under Section 40(a)(ia) of the Income Tax Act. The Pune bench of Income Tax Appellate Tribunal (ITAT) upheld the order of the assessing officer that warehouse charges paid without deducting Tax Deduction at Source shall be disallowed under Section 40(a)(ia) of Income Tax Act, 1961. Bank Interest not Claimed as Deduction in P & L Account and Showing as Pre-Operative Expenses, No Disallowance u/s 43B: ITAT Shri Laxmipat Surana vs Income Tax Officer CITATION: 2022 TAXSCAN (ITAT) 600

The assessee, Shri Laxmipat Surana, is an individual and engaged in the business of property developers. The assessee filed a return of declaring total income Nil. The Assessing Officer observed that bank interest of Rs.3,55,54,116/- was not paid before the due date of filing of return of income. Therefore the assessing officer disallowed the amount u/s. 43B of the Act. The assessee submitted before the tribunal that out of the total bank interest payable at Rs.3,55,54,116/-, which was not paid by the assessee, only a sum of Rs. 54,07,493/- has been claimed by the assessee in the P & L account. Therefore, the Kolkata Bench of Income Tax Appellate Tribunal has held that no disallowance u/s 43B, since bank interest not claimed as deduction in profit and loss account and showing as pre-operative expenses. Loan received through State Government does not attract S.43B(d) of Income Tax Act: ITAT Tokai Sahakari Sakhar Karkhana Ltd vs The Income Tax Officer CITATION: 2024 TAXSCAN (ITAT) 398 The assessing officer disallowed interest expenses payable to the government of Rs 3,13,44,000/- under section 43B of the Income Tax Act 1961. The assessee appealed against the order before the tribunal. The counsel for assessee submitted the coordinate bench deleted the disallowance by holding such loans received through a state government does not attract section 43B(d) of the Income Tax Act. The Tribunal bench ruled that loan received through the state government does not attract section 43B(d) of the Income Tax Act, 1961.

Read More: https://www.taxscan.in/rulings-on-disallowance-of-interest-under-income-tax-act/486522/