The Tribunal held that the assessee had failed to provide any evidence to prove the commercial advantage derived by the assessee from its subsidiaries. The assessee has neither produced any detail to prove commercial expediency nor proved that the advances were given out of own funds. Order of disallowance was affirmed. (AY. 2011-12 to 2014-15)
BGR Energy Systems Ltd. v. ACIT (2022) 96 ITR 625 (Chennai) (Trib) ACIT v. Sasikala Raghupathy (Smt) (2022)96 ITR 625 (Chennai) (Trib)
S. 36(1)(iii) : Interest on borrowed capital-Loans and Advances to subsidiaries without charging Interest-Failure to prove for Commercial expediency-Disallowance of interest justified. [S. 37(1)]