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The ITAT allowed the appeal of the assessee. Disallowance under s.14A read with r.8D was deleted as assessee's own funds exceeded investments, permitting presumption investments were from own funds. Payments of commission were held not excessive and allowable. Additions under s.36(1)(iii) in respect of inter-company transactions were deleted as bona fide business dealings, not loans. Suo-moto disallowances made in the return under r.8D(2)(ii) and r.8D(2)(iii) were ordered deleted; r.8D(2)(iii) computations confined to investments yielding exempt income and AO directed to verify calculations. Advances to subsidiary/sister concerns held commercially expedient; AO directed to delete related interest disallowances.
The ITAT allowed the appeal of the assessee. Disallowance under s.14A read with r.8D was deleted as assessee's own funds exceeded investments, permitting presumption investments were from own funds. Payments of commission were held not excessive and allowable. Additions under s.36(1)(iii) in respect of inter-company transactions were deleted as bona fide business dealings, not loans. Suo-moto disallowances made in the return under r.8D(2)(ii) and r.8D(2)(iii) were ordered deleted; r.8D(2)(iii) computations confined to investments yielding exempt income and AO directed to verify calculations. Advances to subsidiary/sister concerns held commercially expedient; AO directed to delete related interest disallowances.
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