The Assessing Officer disallowed interest alleging diversion of borrowed funds towards interest-free loans advanced to group concerns. The Tribunal held that identical disallowances in the assessee’s own case had been deleted in earlier assessment years and there was no change in the factual position. Following the earlier orders, the disallowance of interest was deleted. (AY.. 2003-04, 2006-07 & 2011-12 to 2015-16).
SIEL Ltd. v. Dy. CIT (LTU) (2025) 123 ITR 599 / 173 taxmann.com 278 (Delhi)(Trib.)
S. 36(1)(iii) : Interest on borrowed capital-Business expenditure-Loans to sister concerns-Consistent view in earlier years-Disallowance deleted.[S. 37(1)]
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