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of ITAT upheld the assessee's claim of commercial expediency in providing an interest-free loan to its subsidiary, rejecting the CIT(A)'s narrow interpretation. The tribunal directed the AO to delete the disallowance of interest, recognizing that commercial expediency is not limited to supporting loss-making entities. Regarding payments to foreign nationals, the tribunal ruled that services rendered by non-residents with stay less than 120 days are not taxable in India. The AO's disallowance of payments was overturned, with the tribunal finding no requirement for TDS or section 195(2) certificate, as the payments were not chargeable to tax in India. The decision substantially favored the assessee's tax treatment.
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