TaxTMI 
TaxTMI 
2026 (4) TMI 393
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....CA. For the Respondent : Ms. Ankush Kalra, Senior DR. ORDER PER AMITABH SHUKLA, AM This appeal by the assessee is directed against the order of learned CIT(A), National Faceless Appeal Centre, Delhi dated 24th December, 2024. 2. The only issue involved in this appeal by the assessee is relating to the disallowance of interest expenses of Rs.43,86,674/- by invoking the provisions of ....
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....ch interest was paid were utilized for the purpose of business and that the advance was given for purchase of industrial property and the same was being acquired for business purposes. However, being not satisfied by the explanation of the assessee, the assessment proceedings were completed by disallowing Rs.43,86,674/- being interest on loan under Section 36(i)(iii) of the Act, which were confirm....
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.... duly substantiated that long term advance against property was a business advance. The advances were also given in the earlier years and the unsecured loan on which interest was paid were taken during the year under consideration and were used for business purposes of the assessee company. He also submitted that the initiation of penalty proceedings and charging of interest are also bad in law. V....
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....8. It is, therefore, clear that the borrowed funds on which interest was paid have no relation to the advances given by the assessee company. Further, the advancement of non-interest-bearing funds as loans and advances cannot be any reason for presuming that the assessee company had advanced interest-bearing funds as loans and advances. The assessee has sufficiently proved that it has own funds to....