2019 (5) TMI 2000

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ircle - 1(1)(2), Baroda for the Assessment Year 2013-14. 2. The assessee, a private limited company engaged in the business of manufacturing of various household plastic products and oral care products, filed its return of income on 30.09.2013 declaring total income at Rs.45,93,140/- upon scrutiny notice dated 01.09.2014 u/s 143(2) of the Act was issued followed by a notice u/s 142(1) dated 05.01.2015 along with a detailed questionnaire and served upon the assessee. The assessee has given interest free advances to its sister concern M/s. Amigo Dispensing Solutions Pvt. Ltd. for business purpose, which was from its borrowed funds. The same was provided with a clear intention of commercial purpose. The assessee is also having sufficient inte....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....assessee to show as to why interest income of the interest free loans and advanced should not be disallowed. In response to the query of the AO, assessee filed a detailed reply wherein it took two fold pleas. In the first fold of contentions, it was submitted that advances were given to the sister concerns on account of business exigency and in the second fold, it was contended that the assessee has sufficient interest free funds, out of which, it could be construed that, these advances were given. The ld.AO did not accept these contentions of the assessee and made disallowance of Rs.9,42,268/- in the Asstt.Year 2010-11 and Rs.6,82,954/- in the Asstt.Year 2011-12. Appeal to the ld.CIT(A) did not bring any relief to the assessee. 4. The l....