Held, that the assessee could not controvert the finding of the Commissioner (Appeals) and as to how the proportionate disallowance on average outstanding computed by the Commissioner (Appeals) at 0.88 per cent. was unreasonable because there was no business transaction declared by the assessee from these parties. The Commissioner (Appeals) had rightly computed proportionate interest on average outstanding. (AY. 2014-15).
Saranya Agro Foods Pvt. Ltd. v. ITO (2023)101 ITR 60 (SN)(Chenni) (Trib)
S. 36(1)(iii) :Interest on borrowed capital-Interest free loans-no business transaction with parties-Notional interest computed at 0.88 % on average-Reasonable.