2002 (11) TMI 75 - DELHI HIGH COURT

Interest On Borrowed Capital - "(a) Whether, on the facts and in the circumstances of the case, the Tribunal was incorrect, both on facts and in law, in holding that the interest paid by the assessee to the SBI was admissible deduction and no part of it could be disallowed? - (b) Whether the learned Income-tax Appellate tribunal was correct in law and on the facts of the case in concluding that no interest paid to the State Bank of India can be disallowed because of interest-free loans advanced to the sister concern, free of interest? - (c) Whether the order passed by the learned Income-tax Appellate Tribunal is perverse in facts and in law?" - Tribunal has also noted that the Departmental Representative could not point out any specific interest bearing borrowed funds, which had been diverted by the assessee to its sister concern. - The aforenoted findings of the Tribunal being based on the relevant evidence on record, no question of law, much less a substantial question of law, arises from the orders of the Tribunal. It is not shown to us as to which finding of the Tribunal is either without any evidence or material or it is contrary to the evidence, to term it as perverse