Interest Disallowance Under Sec 36(1)(iii): Use Average Interest Rate for Fair Tax Assessment on Borrowed Funds.

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....Disallowance under section 36(1)(iii) - There is no justification either for the assessee or for the department to take into consideration the rate of interest in respect of a particular advance or advances to the assessee. The only logical approach is to take into consideration the average interest rate at which the assessee has availed of the advances. - HC....