TMI Blog1983 (6) TMI 50X X X X Extracts X X X X X X X X Extracts X X X X ..... non-trading purposes. 2. The assessee firm deals in printing and selling saries on wholesale basis. During the course of the assessment proceedings, the ITO found that that the assessee had advanced an amount of Rs. 3,51,219 to a sister concern by the name of M/S Khemee dyeing and Bleaching Works and no interest was charged there on. The assessee explained before the ITO that the amount was gi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... further the partners had adequate capital balance for advancing the loan to the other party. 3. On an appeal by the revenue before the tribunal it is submitted that the CIT(A) had erred in holding that there was no evidence to conclude that the borrowed funds were diverted for non/business use when in fact the capital account of the partners showed drawings of only Rs. 69,602 against the loan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... advance was Rs. 2,53,323 only. As against this net advance of Rs. 2 lacs and add, the total opening credit balance of the partners during the year amounted to Rs. 3,94,442 and the closing balance amounted to Rs. 4,43,142. It is further pointed out that the revenue has not been able to point out that any single interest bearing loan was advanced taken in respect of the loan to be advanced to M/s K ..... X X X X Extracts X X X X X X X X Extracts X X X X
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