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2012 (9) TMI 249 - ITAT HYDERABADDisallowance u/s. 40(a)(ia) - non deduction of TDS on interest payment - Held that:- As decided in ITO v. Parag Mahasukhlal Shah [2011 (6) TMI 148 - ITAT, AHMEDABAD] that a payment which has direct link and immediate nexus with the trading liability being connected with the delayed purchase payments will not fall within the category of interest as defined in section 2 (28A) - as the interest paid by assessee is not for any loan or debt incurred by the assessee but for the delay in payment of bills for purchases effected cannot be termed as interest as defined u/s. 2 (28A) - no disallowance could be made u/s. 40 (a) (ia) - in favour of assessee. Disallowance of interest paid by the assessee on borrowals - Held that:- No addition of proportionate interest on interest free advance can be called for on the self same interest free advance made - in favour of assessee.
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