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2014 (9) TMI 1030 - HC - Income TaxDisallowance under section 40A(2)(b) - rate of interest - Held that:- As the assessee has borrowed funds and used the same for its business purposes. Both, the Commissioner (Appeals) as well as the Tribunal have concurrently found that the borrowed funds have been used for business purposes and have held that interest on such borrowed funds is an allowable expenditure. The only difference in opinion is to the extent of interest allowable on such borrowed funds. The Commissioner (Appeals) has restricted such allowance to the interest paid to transporters and towards ‘goods deposits’ whereas the Tribunal has held the interest paid at the rate of 18% to be reasonable. Having regard to the findings recorded by the Tribunal for holding the rate of interest at 18% to be reasonable, it is not possible to state that there is any legal infirmity in the conclusion arrived at by the Tribunal so as to give rise to a question of law, much less, a substantial question of law, warranting interference.
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