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    <title>2025 (4) TMI 1453 - ITAT HYDERABAD</title>
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    <description>ITAT Hyderabad partially allowed the assessee&#039;s appeal regarding interest expense disallowance under Section 36(1)(iii). The tribunal held that investment in sister concern was not a loan, and since it was funded through interest-free director investments rather than borrowed funds, no interest disallowance was warranted. However, for advances to another group company, the tribunal upheld the disallowance as the assessee failed to prove commercial exigency or business connection between companies, treating it as loan subject to interest restrictions for the actual loan period only.</description>
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    <pubDate>Thu, 24 Apr 2025 00:00:00 +0530</pubDate>
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      <title>2025 (4) TMI 1453 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=769539</link>
      <description>ITAT Hyderabad partially allowed the assessee&#039;s appeal regarding interest expense disallowance under Section 36(1)(iii). The tribunal held that investment in sister concern was not a loan, and since it was funded through interest-free director investments rather than borrowed funds, no interest disallowance was warranted. However, for advances to another group company, the tribunal upheld the disallowance as the assessee failed to prove commercial exigency or business connection between companies, treating it as loan subject to interest restrictions for the actual loan period only.</description>
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      <pubDate>Thu, 24 Apr 2025 00:00:00 +0530</pubDate>
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