https://www.taxtmi.com/caselaws?id=752635 The ITAT Chandigarh upheld CIT(A)'s decision favoring the assessee on two issues. First, regarding interest disallowance u/s 36(1)(iii), the AO's contention that a Rs. 90 lacs advance to an individual lacked business purpose was rejected. CIT(A) found the advance was made for purchasing corporate office premises with proper documentation, existing business relationship, and genuine commercial purpose. The AO's presumptions without evidence were insufficient for disallowance. Second, concerning higher deduction u/s 80IC, the AO alleged profit diversion to subsidiary entity was dismissed. CIT(A) accepted the assessee's explanation for GP rate fall, noting consistent departmental acceptance of cost-plus pricing method for related party transactions under excise rules. Both decisions favored the assessee. en-us Tue, 23 Jan 2024 00:00:00 +0530 Wed, 15 May 2024 14:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752635 The ITAT Chandigarh upheld CIT(A)'s decision favoring the assessee on two issues. First, regarding interest disallowance u/s 36(1)(iii), the AO's contention that a Rs. 90 lacs advance to an individual lacked business purpose was rejected. CIT(A) found the advance was made for purchasing corporate office premises with proper documentation, existing business relationship, and genuine commercial purpose. The AO's presumptions without evidence were insufficient for disallowance. Second, concerning higher deduction u/s 80IC, the AO alleged profit diversion to subsidiary entity was dismissed. CIT(A) accepted the assessee's explanation for GP rate fall, noting consistent departmental acceptance of cost-plus pricing method for related party transactions under excise rules. Both decisions favored the assessee. Case-Laws Income Tax Tue, 23 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752635