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The ITAT upheld in part the AO's disallowance: where the assessee borrowed at 12% and advanced interest-bearing loans at 5% to five related entities, a 7% interest disallowance is warranted and the AO is directed to compute and quantify that disallowance. For other advances, the ITAT required the assessee to produce a cash-flow statement and full particulars of loans squared-off to enable the AO to segregate interest-bearing funds from interest-free funds; disallowance is to be computed only to the extent interest-bearing funds were advanced interest-free. The AO must also reassess interest under section 234A only from the extended filing due date.
The ITAT upheld in part the AO's disallowance: where the assessee borrowed at 12% and advanced interest-bearing loans at 5% to five related entities, a 7% interest disallowance is warranted and the AO is directed to compute and quantify that disallowance. For other advances, the ITAT required the assessee to produce a cash-flow statement and full particulars of loans squared-off to enable the AO to segregate interest-bearing funds from interest-free funds; disallowance is to be computed only to the extent interest-bearing funds were advanced interest-free. The AO must also reassess interest under section 234A only from the extended filing due date.
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