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Interest-free advances to sister concern allowed despite borrowing costs under section 36(1)(iii) when commercial expediency established

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Full Text of the Document

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....ITAT dismissed revenue's appeal regarding disallowance under section 36(1)(iii) for interest-free advances to sister concern. Assessee company provided interest-free loan to sister concern while claiming interest deduction on secured loans from banks and financial institutions. CIT(A) deleted additions after examining remand report, finding no evidence that advances were made for non-business purposes. CIT(A) noted investee company regularly paid advance tax with effective tax rate exceeding assessee's rate. ITAT upheld CIT(A)'s decision, concluding the issue was examined correctly and additions were rightly deleted, establishing commercial expediency justified the interest-free advances despite simultaneous borrowing costs.....