Accommodation-entry interest is disallowed, but tax withholding is excluded and unsupported estimated commission additions fail.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Interest claimed on unsecured loans admitted to be bogus accommodation entries is treated as non-deductible as a consequential matter. The tax deducted at source component of such interest must be excluded from the disallowance. Estimated commission additions for obtaining accommodation entries require corroborative evidence of payment or a reliable basis for estimation; a presumption alone is insufficient. Accordingly, the interest disallowance is retained after excluding tax deducted at source, while the commission additions are deleted.....