TMI Blog2001 (8) TMI 980X X X X Extracts X X X X X X X X Extracts X X X X ..... d by the revenue against the order of the DCIT(A) deleting the disallowance of Rs. 21,000 made by the Assessing Officer out of interest expenditure of the assessee. 2. According to the Assessing Officer, the assessee had advanced interest free loan to its sister concern namely M/s. Kesharinandan Ganeriwal and has paid substantial interest to its creditors. As the advancing of the loan to said si ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ported the order of the Assessing Officer and on the other hand the AR supported the order of the DCIT(A) and argued that as there was no nexus between the capital borrowed by the assessee on interest and interest free advance made by the assessee, all the interest paid by the assessee is allowable as deduction. 5. After considering the facts and circumstances of the case and also the rival subm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... saved and utilised on some substantive matters, it would be apt to quote the observation of Delhi High Court in the case of CIT v. ITAT ([1998] 232 ITR 207, 216) as below : "The Central Board of Direct Taxes instructions are binding on the Department. If the case at hand is covered by a policy laid down by the Central Board of Direct Taxes in that case no fault can be found with the order of th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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