TaxTMI 
TaxTMI 
2015 (3) TMI 844
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....er Section 260A of the Income Tax Act, 1961 (the Act), challenges the order dated 29th August, 2012 passed by the Income Tax Appellate Tribunal (the Tribunal) for the Assessment Year 2007-08. 2 The Revenue has formulated the following question of law for our consideration: "Whether, on the facts and the circumstances of the case and in law, the Tribunal was justified in holding that the interest....
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....the Commissioner of Income Tax (Appeals) [CIT(A)] recorded a finding of fact that during the Assessment Year 2007-08, the RespondentAssessee had trade transaction with its group concern - M/s. Suraj Diamonds Consultancy Private Limited. In spite of the holding that there was business relationship between the two, the interest paid was disallowed on the ground that the advance was given in June 200....
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.... case of another group concern of the Respondent Assessee was not appropriate as the particular facts such as the date of the loan, the date it was advanced and the manner in which the amounts were utilized by the group concern etc., are not brought on record. Moreover, it is also submitted that the decision of the Supreme Court in S. A. Builders v/s. CIT 288 ITR 1 on which reliance is place....
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....up concern - M/s. Suraj Diamonds Consultancy Pvt. Ltd. during the subject Assessment Year i.e. A. Y. 2007-08. Once the fact of business relationship between the Respondent Assessee and the group concern is established and accepted, then the amount advanced by the Respondent Assessee to its group concern would result in allowing of interest expenditure incurred by the Respondent-Assessee on the amo....