Borrow at 12%, Lend at 5% ITAT Kolkata Partly Upholds Interest Disallowance

Raj Kumar Goenka Vs DCIT (ITAT Kolkata) Borrow at 12%, Lend at 5% ITAT Kolkata Partly Upholds Interest Disallowance – Interest-Free Funds Presumption Applied – ITAT Kolkata Remands Excess Disallowance for Verification Assessee  filed return declaring income of ₹1.18 crore. AO selected the case under CASS for large deduction claimed u/s 57 & after scrutiny, disallowed ₹89.61 lakh. AO noted that Assessee borrowed ₹15.27 crore at 10.67% & advanced loans of ₹46.34 crore at 4.79%, holding that no prudent person borrows at higher rate to lend at lower rate. Excess claim of i...