2017 (8) TMI 1511

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....ibunal, Amritsar Bench, Amritsar (hereinafter referred to as "the Tribunal") in ITA No. 534(Asr)/2014 for the assessment year 2010-11, claiming the following substantial questions of law:- (i) Whether on the facts and in the circumstances of the case, the Hon'ble Income Tax Appellate Tribunal, Amritsar Bench, Amritsar has erred in deleting the addition of Rs. 1,22,51,965/- on account of disallowance of interest expenditure, ignoring the specific finding of the CIT(A) that the assessee had not even attempted to show that the investments in sister concerns served any business purpose? (ii) Whether on the facts and in the circumstances of the case, the Hon'ble Income Tax Appellate Tribunal, Amritsar Bench, Amritsar ha....

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....22.11.2012 under Section 142(1) of the Act along with questionnaire was issued to the assessee. During the course of assessment proceedings, it was, inter alia, noticed that an amount of Rs. 23,23,31,000/- was standing as investments in various related sister concerns but the assessee had not received any interest or return on account of such investments. It was further noticed that after making advances, the assessee itself had applied for interest linked loans and was bearing the interest burden. It was also observed that if the assessee had excess surplus funds then there was no need to take interest bearing loans. The Assessing Officer vide assessment order dated 28.3.2013 (Annexure A-I) disallowed the interest expenditure of Rs. 1,22,5....