TMI Blog2003 (3) TMI 33X X X X Extracts X X X X X X X X Extracts X X X X ..... fact. No substantial question of law does arise for consideration. Otherwise also, the finding of fact of the Tribunal that interest-free loan to its four subsidiaries was not for the purpose of business is not perverse, nor there was any justification to pay huge amount of interest on the borrowings and advance the loan to its subsidiaries at free of interest. No interference is called for in th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 0 under section 36(1)(iii) of the 1961 Act is justified on the ground that no direct nexus is proved between the interest-free advances received from M/s. Gillette U.K. Ltd. and interest-free advances given to subsidiary companies when the nexus is not only evident from the bank statements but is also accepted by the Department in their remand report? Whether the learned Income-tax Appellate Tri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iii) of the 1961 Act is justified on the ground that no direct nexus is proved between the interest-free advances received from M/s. Gillette U.K. Ltd. and interest-free advances given to subsidiary companies when the nexus is not only evident from the bank statements but is also accepted by the Department in their remand report? Whether the learned Income-tax Appellate Tribunal was justified in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and Rs. 73,27,616 in the assessment year 1990-91. The assessee claimed deduction of this interest in these two assessment years on the ground that the assessee wants to have control over another company, i.e., M/s. Sharpedge Ltd., after purchasing its shares. The Tribunal found that it is not the business of the assessee to purchase and sale of the shares. Admittedly, the assessee has paid the h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al question of law does arise for consideration. Otherwise also, the finding of fact of the Tribunal that interest-free loan to its four subsidiaries was not for the purpose of business is not perverse, nor there was any justification to pay huge amount of interest on the borrowings and advance the loan to its subsidiaries at free of interest. No interference is called for in the order of the Trib ..... X X X X Extracts X X X X X X X X Extracts X X X X
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