Promissory note presumption of consideration survives blank-signature and income-tax non-disclosure objections when admissions and attesting evidence ...
Charitable registration cancellation: limitation and jurisdiction upheld, but withdrawal quashed under discontinued provisions for skill-development e...
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Disallowance of interest difference between the rate paid on borrowed capital and the rate advanced to a wholly owned subsidiary is not warranted. The Supreme Court in S.A. Builders held that advancing funds by a holding company to its subsidiary for commercial expediency does not warrant disallowance of interest, even if not charged. The Delhi Tribunal in Moonrock Hospitality ruled that where funds were advanced to a wholly owned subsidiary for business purposes, no interest paid on borrowed funds could be disallowed u/s 36(1)(iii) of the Income Tax Act. Following these precedents, the Tribunal held that no disallowance of interest paid on borrowed funds was permissible and directed the Assessing Officer to delete the addition.
Disallowance of interest difference between the rate paid on borrowed capital and the rate advanced to a wholly owned subsidiary is not warranted. The Supreme Court in S.A. Builders held that advancing funds by a holding company to its subsidiary for commercial expediency does not warrant disallowance of interest, even if not charged. The Delhi Tribunal in Moonrock Hospitality ruled that where funds were advanced to a wholly owned subsidiary for business purposes, no interest paid on borrowed funds could be disallowed u/s 36(1)(iii) of the Income Tax Act. Following these precedents, the Tribunal held that no disallowance of interest paid on borrowed funds was permissible and directed the Assessing Officer to delete the addition.
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