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2018 (12) TMI 1747 - HC - Income TaxReopening of assessment u/s 147 - reasons to believe - interest on borrowed capital from sister concerns - HELD THAT:- Tribunal in the impugned order has specifically recorded that the question of disallowance of interest paid in view of interest free loans and investment by way of share application money in sisters concerns was raised and examined by the AO during the original assessment proceedings. The said findings of fact have not been challenged before us as perverse or contrary to evidence and material on record. This being the factual position, the impugned order does not require interference as it is in consonance with the ratio and law laid down by the Supreme Court in Commissioner of Income Tax versus Kelvinator of India Limited [2010 (1) TMI 11 - SUPREME COURT] and the Full Bench decision of the Delhi High Court in Commissioner of Income Tax versus Usha International Limited, [2012 (9) TMI 767 - DELHI HIGH COURT] - No substantial question of law.
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