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    <title>2008 (2) TMI 660 - ITAT DELHI</title>
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    <description>The appeal was allowed as the Tribunal concluded that interest paid at 18% to related parties was not excessive or unreasonable, considering it was also paid to unrelated parties. The Assessing Officer&#039;s disallowance of interest under section 40A(2)(b) was overturned, emphasizing that reasonableness should be judged based on fair market value and legitimate business needs. The Tribunal highlighted that the AO can only disallow the excessive portion of expenditure and not the entire amount, emphasizing a businessman&#039;s perspective over the revenue&#039;s in assessing commercial expediency.</description>
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    <pubDate>Fri, 15 Feb 2008 00:00:00 +0530</pubDate>
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      <title>2008 (2) TMI 660 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=120611</link>
      <description>The appeal was allowed as the Tribunal concluded that interest paid at 18% to related parties was not excessive or unreasonable, considering it was also paid to unrelated parties. The Assessing Officer&#039;s disallowance of interest under section 40A(2)(b) was overturned, emphasizing that reasonableness should be judged based on fair market value and legitimate business needs. The Tribunal highlighted that the AO can only disallow the excessive portion of expenditure and not the entire amount, emphasizing a businessman&#039;s perspective over the revenue&#039;s in assessing commercial expediency.</description>
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      <pubDate>Fri, 15 Feb 2008 00:00:00 +0530</pubDate>
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