2023 (2) TMI 913

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.... 2. The assessee has raised the following grounds of appeal:- "1) For that on the facts and circumstances of the case, Ld. CIT (Appeals) was grossly erred in confirming the disallowance of interest paid Rs. 11,74,989/- made by Assessing Officer in the assessment completed U/s 143(3) of the Act. 2) For that on the facts and circumstances of the case, Ld. CIT (Appeals) as well as Ld. A.O. failed to bring on record any correlation between unsecured loans taken and its utilization in giving interest free loans and advances to justify the disallowance of interest paid on unsecured loan Rs. 11,74,989/-. 3) For that on the facts and circumstances of the case Ld. CIT (Appeals) failed to appreciate that there were apparent utilization of bo....

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....st expenditure of Rs.11,74,986/- deserves to be disallowed. 4.1. Aggrieved the assessee carried the matter in appeal before the ld. CIT(A) but failed to succeed. 5. Further aggrieved, the assessee is in appeal before this Tribunal. 6. The ld. Counsel for the assessee referring to the written submission filed before the ld. CIT(A) as well as audited financial statements for financial year 2011-12, stated that the assessee had a sufficient interest free funds to the tune of Rs.25.98 Crores at the year-end which was sufficient to apply for giving interest free loans and advances. On the other hand, the ld. D/R supported the orders of the lower authorities. 7. We have heard rival contentions and perused the records placed before us. Disall....