Interest Disallowance u/s 36(1)(iii) Overturned: No Evidence of Misuse of Interest-Bearing Funds for Interest-Free Loans.

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....Disallowance of interest u/s 36(1)(iii) towards interest expenditure - allegation that assessee company diverted its “interest bearing funds” for giving “interest free advances / loans” for unknown purpose - CIT-A deleted the addition - the Assessing Officer merely on an ad hoc basis made the additions under section 36(1)(iii) of the Act, without bringing anything on record to suggest that interest-bearing funds were actually utilised for the purpose of advancing funds on which no interest was charged by the assessee. - order of CIT(A) sustained. - AT....