Ad hoc disallowance made out of the interest paid by the...

Ad hoc disallowance made out of the interest paid by the assessee - No comparable case was cited, wherein the rate of interest less than 12% was paid to the persons from whom unsecured loan was raised. It is also not the case of the department that the loans received by the assessee were used elsewhere and not for the business purpose. In the instant case, it is an admitted fact that 80% of the payment of interest was considered as genuine by the AO and the remaining amount was disallowed without any basis. - Additions deleted - AT