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2017 (10) TMI 479 - AT - Income TaxDisallowance of interest expenditure - Held that:- It is admitted position that the partner’s capital during the year in appeal are not interest-free funds at the disposal of the partnership-firm. The profit belongs to partner and gets added to the capital on which interest is payable by the firm. On these facts, we do not see any purpose of sending the issue back to the file of CIT(A). The assessee has not been able to justify before us as to what facts required to be re-examined by the Revenue. It is the assessee which has failed to discharge the onus in spite of specific opportunities in this regard. We are of the view that assessee has not been able to make out any demonstrable case to show the availability of interest-free funds at its disposal to support its claim for remitting the matter back to the file of the CIT(A).
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