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The ITAT allowed the assessee's appeal, reversing the AO's disallowance of gold hire charges. The Tribunal found that the assessee company had valid Gold Hire Agreements with directors and related parties, with clear covenants for payment of Rs. 5/- per gram per month plus security deposits. The arrangements were properly documented in the balance sheet as loans and hire gold interest paid. The Tribunal accepted that the company had no stock-in-trade of its own and used the hired gold for business purposes. The ITAT determined that paying hire charges of Rs. 41,85,000/- was more economical than taking bank loans at 12% interest (approximately Rs. 1,08,00,000/-) to purchase equivalent stock worth Rs. 9,76,12,546/-.
The ITAT allowed the assessee's appeal, reversing the AO's disallowance of gold hire charges. The Tribunal found that the assessee company had valid Gold Hire Agreements with directors and related parties, with clear covenants for payment of Rs. 5/- per gram per month plus security deposits. The arrangements were properly documented in the balance sheet as loans and hire gold interest paid. The Tribunal accepted that the company had no stock-in-trade of its own and used the hired gold for business purposes. The ITAT determined that paying hire charges of Rs. 41,85,000/- was more economical than taking bank loans at 12% interest (approximately Rs. 1,08,00,000/-) to purchase equivalent stock worth Rs. 9,76,12,546/-.
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