CIT v. Apollo Tyres Ltd. (No. 2) (2019) 219 ITR 546 (Ker.)(HC)

S. 36(1)(iii) : Interest on borrowed capital–Commercial expediency-Inter-corporate deposits–Lower rate charged on inter-corporate deposits than that paid -No disallowances can be made. [S. 37(1)]

Dismissing the appeal of the revenue the Court held that the due to commercial expediency charging of lower rate of  interest on intercorporate deposits than that paid by assessee is held to be justified . There cannot be any universal rate or rule in this regard. No question of law arises.   (AY. 1994 -95)