2009 (12) TMI 983

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....on finding of fact, which is clear from the following observations of the Tribunal: "14. We have carefully considered the rival contentions in the light of material placed before us. Though it has been the case of the AO that assessee utilized interest bearing funds for advancing interest free loans, but no nexus have been established by the AO to say so. As against that assessee has show....

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....footing as no link has been found or established to advance interest free advances from interest bearing funds. We decline to interfere in the disallowance of Rs. 37,76,204/-. 15. On the second issue i.e., interest payment made to DDA of Rs. 9,64,267/-, the same was contended to be non-penal in nature. It was on account of delayed payment of arrears of ground rent. Unless it is an expendi....