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Interest Expenditure Disallowance Unwarranted Due to Minor Rate Difference u/s 40A(2)(b) of Income Tax Act.

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Full Text of the Document

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....Disallowance of interest expenditure by applying provisions of section 40A(2)(b) - Specified / Related parties - Difference between the interest paid by assessee at 15% and the reasonable rate of interest ultimately allowed by learned Commissioner (Appeals) at 13.73% works out to a negligible amount of 1.27%. That being the case, in my considered opinion, the provisions of section 40A(2)(b) would not be applicable in the present case - AT....