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2018 (3) TMI 1092 - AT - Income TaxDisallowance on account of interest attributable to the interest free advance given by the assessee - Held that:- We find merit in the contention of the learned counsel for the assessee and direct the A.O. to compute the interest to be disallowed as per the direction of the CIT(A) given in the impugned order @ 13% instead of 15%. Disallowance made by the A.O. on account of interest accordingly was sustained in A.Y. 2009-10 to the extent it was attributable to the balance amount of ₹ 51,00,000/- advanced to M/s. Phool Commercial Pvt. Ltd. Since the said amount which remained outstanding in the immediately preceding year was paid by the assessee during the year under consideration before 14.10.2009, the disallowance on account of interest attributable to the said amount was liable to be made for the period from 01.04.2009 to the time when the said amount had been returned back by M/s. Phool Commercial Pvt. Ltd. to the assessee company during the year under consideration. We, therefore, find no infirmity in the impugned order of the Ld. CIT(A) directing the A.O. to disallow interest attributable to the amount of ₹ 51,00,000/- advanced by the assessee company to M/s. Phool Commercial Pvt. Ltd. for the period from 01.04.2009 till the date when such amount has been refunded by M/s. Phool Commercial Pvt. Ltd. in the year under consideration @ 13% P.A.
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