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2014 (5) TMI 276 - AT - Income TaxDisallowance of interest – Return of income declaring loss – Held that:- Following SA BUILDERS LTD. Versus COMMISSIONER OF INCOME-TAX [2006 (12) TMI 82 - SUPREME COURT] - The expression “commercial expediency” is one of wide importance and includes such expenditure as a prudent businessman it incurs for the purpose of business - The expenditure may not have been incurred under any legal obligation, but yet it is allowable as business expenditure if it was incurred on grounds of commercial expediency - an order without reasons is as good as no order - the issue of non-interest bearing fund and interest bearing fund had no relevance to decide the tax liability of the assessee - the FAA does not reveal the reasons for upholding the order of the AO – thus, the matter is remitted back to the FAA for fresh adjudication – Decided in favour of Assessee.
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