Dismissing the appeal of the revenue the court held that it is not for the Revenue authorities to substitute their own wisdom or notion about the rate of interest agreed to between the parties, including group companies and as such, the finding of fact about commercial expediency or absence thereof is a finding of fact, out of which no substantial question of law can be said to arise.( AY.2013-14)
CIT v. Shriram Investments (2019) 104 CCH 0737 /(2020)422 ITR 528 (Mad) (HC)
S.36(1) (iii): Interest on borrowed capital — Amount borrowed advanced at lower interest — Revenue authorities cannot substitute their own wisdom or notion about the rate of interest agreed to between the parties – Interest is deductible .