Disallowed interest on interest-free loans to related parties. Onus on assessee to prove commercial expediency. Failed to justify.

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....Addition of interest on interest free loans advanced by assessee Company to sister concerns/related parties disallowed. Onus on assessee to prove commercial expediency for advances taken interest free from related parties. Assessee failed to substantiate commercial expediency for interest free advance to related party M/s. Diehard Dies Pvt. Limited. CIT(A) erred in considering transaction arose out of business/commercial expediency. Order of CIT(A) set aside, restoring AO's order. Revenue's appeal allowed.....