2019 (7) TMI 1972

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....n of income for the AY 2012-13 on 28/09/2012 admitting loss of Rs. 13,66,338/- under normal provisions and book profits u/s 115JB amounting to Rs. 81,21,589/-. Pursuant to the scrutiny under CASS, the assessee's case was taken up for proceedings u/s 143(3) of the Act. 2.1 After examination of the information furnished by the assessee during the assessment proceedings, the AO observed that the assessee has given interest free advance of Rs. 6,03,39,031/- to United Steel Allied Industries Pvt. Ltd. (USAIPL). He observed that the assessee had incurred financial charges amounting to Rs. 3,90,18,229/- on account of borrowed funds and since it had huge burden of finance cost, giving interest free advances to its holding company is not a pruden....

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....g grounds of appeal: "1. The order of the learned CIT (Appeals), in so far as it is prejudicial to the interest of the appellant, is against law, weight of evidence and probabilities of the case. 2. The learned CIT(Appeals) grossly erred in disallowing finance cost @ 12% on the advance given to United Steel Allied Industries Pvt Ltd (USAIPL) of Rs 72,04,684/- overlooking the fact that that the appellant had given the money to USAIPL for construction of a super specialty hospital in Vijayawada with an intention to acquire shares in that company. 3. The learned CIT(Appeals) failed to appreciate that the advances given by the appellant are used for business purpose for construction of super specialty hospital in Vija....