Interest expenditure - assessee had availed loan at the interest...

Interest expenditure - assessee had availed loan at the interest rate of 12% p.a., whereas, it has advanced loan to a sister concern by charging 9% interest p.a - The assessee’s claim that the rate of interest charged at 9% is more than the prevailing rate of interest on FDRs has not also been found to be false. In such circumstances, if the assessee has parked his surplus fund temporarily by charging interest at 9%, which is more than prevailing rate of interest on FDR, the interest so charged cannot be held to be unreasonable. Therefore, disallowance made out of the interest expenditure is uncalled for. Accordingly delete the disallowance. - AT