The assessee had given interest-free advances amounting to its subsidiary company. The assessee filed a chart indicating the sources of funds for advances made to the subsidiary company in different years to support its view that the advance was given out of its own generated funds. The Assessing Officer did not accept the figures and disallowed proportionate interest on interest-free advances at 26 per cent. of the total interest paid on borrowings.  Tribunal held that, CIT(A) had noted that the advances were out of its own funds and it was given to its own subsidiary company which was in the same line of hotel business as a measure of commercial expediency. (AY. 2004-05).