https://www.taxtmi.com/caselaws?id=176556 The appeal was dismissed as the revenue failed to justify the application of Section 40A(2)(a) of the Income Tax Act. Both the Commissioner (Appeals) and the Tribunal found the 24% interest rate paid to Sun Pharmaceuticals reasonable based on commercial practices. The burden of proof for disallowance lay with the revenue, which was not met. The deletion of the disallowance was upheld as there was no direct relationship established between the appellant and the payee company, and the interest payment was deemed necessary for business needs. en-us Tue, 04 May 2010 00:00:00 +0530 Thu, 24 Dec 2015 17:49:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=176556 The appeal was dismissed as the revenue failed to justify the application of Section 40A(2)(a) of the Income Tax Act. Both the Commissioner (Appeals) and the Tribunal found the 24% interest rate paid to Sun Pharmaceuticals reasonable based on commercial practices. The burden of proof for disallowance lay with the revenue, which was not met. The deletion of the disallowance was upheld as there was no direct relationship established between the appellant and the payee company, and the interest payment was deemed necessary for business needs. Case-Laws Income Tax Tue, 04 May 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=176556