TMI Blog2008 (7) TMI 983X X X X Extracts X X X X X X X X Extracts X X X X ..... spose of three Income-tax Appeals bearing ITA Nos. 571, 572 and 573 of 2007. The revenue has filed these appeals under section 260A of the Income-tax Act (hereinafter referred to as the Act ) against the order dated 16-4-2007 passed by the Income-tax Appellate Tribunal, Chandigarh Bench A (hereinafter referred to as the Tribunal ) in ITA Nos. 196 to 198/Chd./2006 in case of the assessee for th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rest-free loan given to M/s. Gujarat Cycles Limited was for a business consideration. In view of the said finding of fact, the Tribunal while distinguishing the judgment of this Court in CIT v. Abhishek Industries Ltd. [2006] 286 ITR 11, has dismissed the appeal of the revenue while coming to the conclusion that the order of the Commissioner of Income-tax (Appeals) was correct. 3. Counsel for t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nce of interest on the ground that there is no nexus between the borrowings and interest-free advances made to sister concern, cannot be quashed. 5. After hearing the counsel for the parties, we do not find any substance in the arguments raised by the counsel for the revenue. As per section 36(1)(iii) of the Act, the amount of interest paid in respect of capital borrowed for the purposes of the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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