2022 (9) TMI 90

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....venue with Ms. Mansie Jain, Advocate. Respondent Through: Mr. Aditeya Bali, Advocate for Ms. Kavita Jha, Advocate. J U D G M E N T MANMOHAN, J (Oral): 1. Present Income Tax Appeal has been filed challenging the order dated 16th December, 2019 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA No. 4156/Del./2017 for the Assessment Year 2012-13. 2. Learned Counsel for the App....

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....nces included the - investment in the immovable property and was part of the business activity, investment in the partnership firm was made wholly and exclusively for the purpose of the business, the advances recoverable and forward cover receivable included in the advances were business advances and the same were given to the suppliers with whom regular business transactions had been carried out,....

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....dvances which are business advances on which no interest is disallowable. It was also part of the record that another advances interest has been charged by the assessee as found out by the Id. CIT (A) on going through the Schedule 17 of the balance sheet. Since, the loans &  advances have been given on account of commercial expediency and notional interest can be charged on such advances or i....

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....g in view the facts of the case and legal propositions laid down on this aspect of allowability of interest u/s 36(1)(iii), we hereby decline to interefere with the order of the ld. CIT (A). The appeal of the revenue on this ground is dismissed." 5. On the issue of addition of Rs.37,40,940/- made under Section 14A read with Rule 8D, the ITAT observed that the Appellant had own funds of....