No disallowance of interest for loan advanced to Sister Concern out of Share Capital and Reserves

Grounds of appeal by Revenue:

The Revenue, in ITA No. 7758/Mum/2010 & ITA No. 1364/Mum/ 2011, has raised the following grounds of appeal: –

1. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of Rs.18,50,000/- being interest disallowed u/s. 36(1)(iii) of the I.T. Act, 1961, overlooking the failure of the assessee to substantiate that the amounts borrowed were for the purpose of the assessee’

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