DCIT v. Tally Solutions Pvt. Ltd. (2021) 91 ITR 66 (SN) (Bang.)(Trib.)

S. 36(1)(iii) : Interest on borrowed capital-Advance to sister concern-No advances made during the year-Sufficient interest free funds-Addition is not valid on notional basis.

Held that there was no nexus between the borrowed funds and the amounts outstanding in the case of the sister concern. In such factual situation, there could not be any addition. (AY. 2014-15)