2014 (5) TMI 741

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e heard together and are being disposed of with this common order for the sake of convenience. 2. Though as many as five common grounds have been raised by the Revenue in these appeals, the only effective grievance of the Revenue is with regard to the relief granted by the CIT(A) by deleting part of the additions of Rs.152,64,40,695 for the assessment year 2008-09 and of Rs.130,80,19,463 for the assessment year 2009-10, made by the Assessing Officer, by disallowing financial charges paid by the assessee to banks, financial institutions and HUDA. 3. We heard both sides and perused the impugned orders of the Revenue authorities and other material available on record. At the outset, the learned counsel for the assessee brought to our not....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....as not collected any interest from the beneficiaries and also the principal amount in several cases. However, it is fact that some amounts are recovered from the beneficiaries and the same are shown as 'recoveries from the beneficiaries' in the Balance Sheet. There is no dispute with regard to the payment of interest to the bank and financial institutions. The department disallowed the entire interest payment made by the assessee corporation only on the ground that the assessee has not offered any income on interest recovered from its beneficiaries. After considering the totality of facts and the circumstances of the case, we are of the view that the lower authorities are not correct in disallowing the interest payment to various commercial....