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2012 (8) TMI 947 - AT - Income TaxDisallowance of interest paid to banks whereas the assessee had advanced interest free loan to its sister concerns with whom it had no business dealings - Held that:- No where the assessee has established the measure of commercial expediency either before the AO or before the ld. CIT(A) and not even before us. There is nothing on record that the money so advanced by the assessee to the sister concern had been used as a measure of commercial expediency. In the facts and circumstances of the case, the ld. CIT(A) has wrongly interpreted and relied upon the decision of Hon’ble Supreme Court in the case of S.A. Builders Ltd. vs. CIT (2006 (12) TMI 82 - SUPREME COURT) which in fact goes against the assessee. In the facts and circumstances, the order of the Ld. CIT(A) is reversed and that of the A.O. is restored. Thus, all the grounds of the Revenue are allowed.
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