Commercial expediency cannot be mere availing of interest free loan from one assessee and giving interest free loan to another

Facts :- learned Assessing Officer found that the assessee paid interest to the Banks amounting to Rs. 13,64,522/- and has availed loans to the extent of Rs. 60,22,364/- including secured loans of Rs. 47,63,761/- from Punjab & Sind Bank and Rs. 8,59,298/- from Andhra Bank. It was found that the assessee has advanced certain loans to its Directors and also to some Companies under the same Management free of interest. The amount due as on 31.03.1989 is almost equal to the amount of loans taken from the Bank. The Assessing Officer, thus, found that almost the same amount taken from the Banks ...