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2019 (3) TMI 4 - AT - Income TaxAccrual of ‘real income’ - Addition on account of notional interest - share application money remaining without allotment of shares - availability of interest free funds in the hands of assessee by way of Capital Account - HELD THAT:- Where the assessee has own funds and had utilized the same for the purpose of giving advances to different concerns who were related to Apollo Tyres, where the assessee was dealer in tyres of Apollo Tyres Ltd., no adverse inference can be drawn against the assessee. The availability of interest free funds in the hands of assessee by way of Capital Account is not disputed and in such circumstances, where the available funds were much more than interest free advances in the hands of assessee, no disallowance on account of interest expenses is to be made in the hands of assessee. - Decided in favour of assessee.
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