2013 (12) TMI 638

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....ainst order dated 9.8.2011 of ld CIT(A) -27, Mumbai on following grounds:- "1. On the facts and circumstances of the case and in law, ld CIT(A) erred in deleting an amount of Rs.23,39,723/- being the disallowance of interest u/s.36(1)(iii) of the I.T.Act, 1961 debited to the profit and loss account of the assessee, without appreciation that the assessee has not established the commercial expedien....

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....an amount of Rs.1.53 crores by way of share application money in M/s. Pankaj Extrusions Ltd.(PEL), a sister concern. Besides that assesse has also invested an amount of Rs.1 crore in acquisition of shares of M/s. Pankaj Extrusions Ltd. AO also noted that no supporting evidence was furnished to support the contention that borrowed money was utilized for the purposes of business only. Besides, asses....

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....tement furnished by the assessee, the amounts invested with PEL were out of L/C discounting money received by the assessee on which interest was paid. Ld CIT(A) has extracted the statement at page 3 of the impugned order the amount of Rs.2,41,611/- attributable to the transactions in respect of LC discounting money on which interest was paid and observed that the same cannot be allowed as relevant....