https://www.taxtmi.com/caselaws?id=761545 ITAT Pune allowed the assessee's appeal on two grounds. First, regarding disallowance of interest under Section 36(1)(iii) on interest-free loans, the tribunal held that since the assessee's opening capital of Rs. 4,36,06,730.78 was substantially higher than interest-free loans of Rs. 94,70,000, no proportionate disallowance was warranted, following SC precedent in South Indian Bank Ltd. Second, concerning disallowance of proportionate interest where AO restricted interest rates from 17-23% to 15%, the tribunal applied the consistency principle, noting no such disallowances were made in previous assessment years 2014-15, 2016-17, and 2017-18, thereby allowing the excess interest payment of Rs. 4,55,190. en-us Mon, 14 Oct 2024 00:00:00 +0530 Mon, 11 Nov 2024 21:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761545 ITAT Pune allowed the assessee's appeal on two grounds. First, regarding disallowance of interest under Section 36(1)(iii) on interest-free loans, the tribunal held that since the assessee's opening capital of Rs. 4,36,06,730.78 was substantially higher than interest-free loans of Rs. 94,70,000, no proportionate disallowance was warranted, following SC precedent in South Indian Bank Ltd. Second, concerning disallowance of proportionate interest where AO restricted interest rates from 17-23% to 15%, the tribunal applied the consistency principle, noting no such disallowances were made in previous assessment years 2014-15, 2016-17, and 2017-18, thereby allowing the excess interest payment of Rs. 4,55,190. Case-Laws Income Tax Mon, 14 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761545