DCIT v. Piramal Realty (P.) Ltd. (2019) 174 ITD 633 / 198 TTJ 999/ 176 DTR 242 (Mum.) (Trib.)

S. 36(1)(iii) : Interest on borrowed capital-Advance to subsidiary- Commercial expediency-Corporate strategy -Disallowance of part of interest is held to be not justified.

Dismissing the appeal of the revenue the Tribunal held that;  advance of loan to subsidiary due to commercial expediency and corporate strategy, accordingly disallowance of part of interest is held to be not justified. (AY. 2012-13)