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2016 (8) TMI 1349 - ITAT AMRITSARAddition u/s 36(1)(iii) - assessee submitted that the said amount has been invested in the group companies in the larger interest of assessee for business expediency- Held that:- The total of non interest bearing funds as available with the assessee are to the tune of ₹ 84,82,25,180/- against which the assessee had invested as non interest bearing investments to the tune of ₹ 72,28,15,197/-. Therefore, non interest bearing funds are more than non interest bearing investments. Further we find that assessee has declared more interest income on fixed deposits than the interest paid by him on interest bearing funds. In view of the facts and circumstances, it cannot be said that assessee had deployed interest bearing funds into non interest bearing investments. Assessee is a sole proprietor of M/s Modern Publishers and is also a majority shareholders in the companies in which interest free investments has been made. Paper Book page 12 is the list of companies in which the assessee is a holding a major chunk of shares. The rest of the shares are also held by other family members of the assessee. From the above chart it can be safely concluded that assessee is a major shareholder and therefore the advances/investments made by assessee in these companies cannot be said to be without commercial expediency. There would be a direct benefit to the assessee if the interest free investments made in these companies results into more profits to these companies and indirectly to the assessee - Decided in favour of assessee.
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