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2005 (5) TMI 47 - HC - Income TaxInterest on loan given to sister concern - Whether there existed any commercial expediency for the assessee to transfer the said amount to one of its sister concern or not – This question is primarily a question of fact. The contention that the funds were advanced from self-generated funds of the assessee and that there was a need for that purpose, is again a question of fact. It is a settled principle of law that the Tribunal is the final fact-finding authority and the courts while exercising the appellate jurisdiction under section 260A of the Act would not normally interfere with such findings. - Besides the fact that no question of law, much less a substantial question of law arises in the present case, the other predominant factors, which would require dismissal of this appeal are that, from the records no nexus can be traced between the borrowed funds and the interest-free advances made by the assessee to its sister concern. Secondly, it has been clearly established on record that the assessee itself had taken loans with interest and had advanced funds by diversion or otherwise to its sister concern free of interest - held that additions to the extent of "interest" are justified
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