TMI Blog2021 (1) TMI 212X X X X Extracts X X X X X X X X Extracts X X X X ..... submitted before the authorities below as it appears from the order impugned as well as the Paper Book filed before us - we delete the addition made by the authorities below. Disallowance of interest expenses for providing interest free loan for subsidiary company under Section 36(1)(iii) - HELD THAT:- The said issue was settled in view of the judgment and order passed by the Hon ble Supreme Court in the case of SA Builders Ltd [ 2006 (12) TMI 82 - SUPREME COURT ] whereby and whereunder it was decided that in the event the fund is utilized by sister concerns for business purposes it was allowable. Since we do not find any deviation in the facts as available on record before us we find substance in assessee s counsel s submission and th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... transaction with the Dubai and U.S.A. and Bangkok. The assessee s case is this that the directors of the companies visited those places to attend meeting and trade fair. It is relevant to mention that the assessee s business is of manufacturing of dye intermediate and chemicals. In Dubai they attended the Beauty World expo. In U.S.A. they attended a meeting and discussed business proposal at trade fare. In Thailand they attended meeting of YPO Chapter Retreat. All the relevant documents in support of such tours indicating the business purposes of the assessee company were duly submitted before the authorities below as it appears from the order impugned as well as the Paper Book filed before us. Apart from that the case of the assessee on i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ance in assessee s counsel s submission and thus allow the ground by deleting the disallowance of interest expenses of ₹ 12,27,149/-. 4. Assessments of short term capital gain on sale of Mutual Funds of ₹ 24,93,962/- treating it as business income has been challenged before us. At the onset of the hearing, the Ld. Counsel appearing for the assessee submitted before us that issue is covered in favour of the assessee from A.Y. 2003-04 to 2012-13 which is also evident from the order passed by the Ld. CIT(A) at Page 18 and 19. 5. The Ld. DR failed to controvert such submission made by the Ld. AR. Keeping in view the identical facts and in view of the rule of consistency we find no reason in disallowing such sale of Mutual F ..... X X X X Extracts X X X X X X X X Extracts X X X X
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