TMI Blog2009 (12) TMI 983X X X X Extracts X X X X X X X X Extracts X X X X ..... ibunal: 14. We have carefully considered the rival contentions in the light of material placed before us. Though it has been the case of the AO that assessee utilized interest bearing funds for advancing interest free loans, but no nexus have been established by the AO to say so. As against that assessee has shown that whatever interest bearing funds were available with the assessee, none of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ances from interest bearing funds. We decline to interfere in the disallowance of ₹ 37,76,204/-. 15. On the second issue i.e., interest payment made to DDA of ₹ 9,64,267/-, the same was contended to be non-penal in nature. It was on account of delayed payment of arrears of ground rent. Unless it is an expenditure made by the assessee in contravention of some law, the same cannot b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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