The HC set aside deletions of additions relating to notional...

The HC set aside deletions of additions relating to notional interest on advances to subsidiaries, holding that the assessee's reliance on commercial expediency and its later omission to charge interest had not been properly verified and required fresh examination by the appellate authority. It also held that a bad debt claim could not be allowed without an actual write-off in the accounts after 01.04.1989, with party-wise details and relevant records needed to apply the Supreme Court authorities correctly; that issue was remitted for reconsideration. Relief on the amount debited to the share premium account was likewise set aside because the factual basis for deletion under the actual payment requirement was inadequate, and the matter was remanded to the CIT (Appeals).

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