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2019 (3) TMI 362 - HC - Income TaxDisallowance of interest on borrowed funds - commercial expediency - funds diverted for advancing interest-free loans to sister concerns - Tribunal held the pattern of loan extended to sister concerns would qualify business expediency as relying on S.A.Builders Ltv. v. CIT [2006 (12) TMI 82 - SUPREME COURT] - HELD THAT:- In the impugned order passed by the Tribunal, we find that the Tribunal took note of the factual position and held that loans advanced by the assessee was a business expediency. Tribunal has recorded the facts to support its stand that the decision in S.A.Builders would aid the case of the assessee. The CIT(A) was also satisfied with the nature of the transaction and it would qualify as "business expediency". Merely because a reference is pending that does not mean that the decision rendered by the Hon'ble Supreme Court is no longer good law. As pointed out by us earlier, the CIT(A) and the Tribunal has discussed the factual position and held that the transaction would qualify "business expediency". - Decided against revenue
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