Girraj Cold Storage (P) Ltd v. ITO (2025) 174 taxmann.com 342/ 233 TTJ 41 (UO) (SMC) (Agra)(Trib)

S. 36(1)(iii) :Interest on borrowed capital-Interest-free advances given to farmers-Commmercial expediency-Allowable as deduction.

Held that  interest-free advances to farmers, so that they are tied up with the assessee and they keep their crops in the cold storage of the assessee from which it can earn rent, it has to be accepted that the assessee has given said interest-free advances out of commercial expediency and therefore, the disallowance of interest paid by the assessee to the bank is not sustainable. Followed, S.A. Bilders Ltd. vs. CITYA) & Anr. (2006) 206 CTR  631 (SC). (AY. 2011-12)

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