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ITAT allowed the assessee company's appeal on interest disallowance u/s 36(1)(iii), holding that sufficient interest-free own funds were available to cover the investment in its wholly owned subsidiary, following its own precedents in earlier assessment years. The disallowance of proportionate interest at 12.5% on the subsidiary investment was therefore held unwarranted and deleted. On the addition u/s 56(2)(b)(viib) relating to premium on preferential shares, ITAT held that the lower authorities rejected the assessee's valuation on technical grounds and set aside the CIT(A)'s order, directing the assessee to furnish a revised valuation report under Rule 11UA adopting book value of land and remanding the matter to the AO for recomputation.
ITAT allowed the assessee company's appeal on interest disallowance u/s 36(1)(iii), holding that sufficient interest-free own funds were available to cover the investment in its wholly owned subsidiary, following its own precedents in earlier assessment years. The disallowance of proportionate interest at 12.5% on the subsidiary investment was therefore held unwarranted and deleted. On the addition u/s 56(2)(b)(viib) relating to premium on preferential shares, ITAT held that the lower authorities rejected the assessee's valuation on technical grounds and set aside the CIT(A)'s order, directing the assessee to furnish a revised valuation report under Rule 11UA adopting book value of land and remanding the matter to the AO for recomputation.
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