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2021 (10) TMI 222 - AT - Income TaxDisallowance of interest expenditure - Re-shuffling of loan portfolio - Assessee taken loans from Yes Bank Ltd. in earlier years and the same was repaid by borrowing money from a related concern - CIT-A deleted the addition - HELD THAT:- The present loan taken from Standard Chartered Investment & Loans India Ltd. has been used to repay the loan taken from Coffee Day Hotels & Resorts Pvt. Ltd. These facts show that the assessee was only reshuffling its loan portfolio by changing the lenders, i.e., it is not a case, where the assessee has diverted interest bearing funds to its related concerns, as presumed by the A.O. If that be so, then the amount diverted to related concern should have found place in the assets side of the Balance Sheet. We notice that the Ld. CIT(A) has given a clear finding that the asset side of the balance sheet contains only business assets. - Decided against revenue.
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