Moonrock Hospitality (P.) Ltd. v. ACIT (2022) 94 ITR 185 (Delhi) (Trib.)

S. 36(1)(iii) : Interest on borrowed capital-Interest free loans to wholly-owned subsidiary-Commercial expediency-Interest on borrowed capital allowable as deduction.

The Assessee had forwarded interest-free loans to its wholly owned subsidiaries out of its borrowed funds. The Tribunal upheld the order of the CIT(A) and relied upon various judicial precedents on the issue to hold that since the loans were extended for the purpose of its business, interest paid on borrowed funds cannot be disallowed u/s 36(1)(iii) of the Act. (AY. 2016-17).