https://www.taxtmi.com/caselaws?id=397966 ITAT Ahmedabad held that where borrowed funds are diverted to interest-free advances, the assessee must substantiate a lower cost of funds to reduce disallowance under section 36(1)(iii); on the record, the Assessing Officer's average borrowing cost of 11.45% was found consistent with the borrowing pattern and the assessee's lower rate was not supported, so the disallowance was sustained. It also accepted that the Covid-19 lockdown created exceptional circumstances justifying exclusion of the lockdown period for computing the time limit for pronouncement under rule 34(5)(c), making the delayed pronouncement permissible. en-us Mon, 01 Jun 2020 00:00:00 +0530 Thu, 03 Sep 2020 09:47:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=397966 ITAT Ahmedabad held that where borrowed funds are diverted to interest-free advances, the assessee must substantiate a lower cost of funds to reduce disallowance under section 36(1)(iii); on the record, the Assessing Officer's average borrowing cost of 11.45% was found consistent with the borrowing pattern and the assessee's lower rate was not supported, so the disallowance was sustained. It also accepted that the Covid-19 lockdown created exceptional circumstances justifying exclusion of the lockdown period for computing the time limit for pronouncement under rule 34(5)(c), making the delayed pronouncement permissible. Case-Laws Income Tax Mon, 01 Jun 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=397966