No Disallowance once TPO Accepted Arm’s Length Interest Rate on Overseas Loan

ACIT Vs Reliance Coal Resoures Pvt. Ltd. (ITAT Mumbai) The Income Tax Appellate Tribunal, Mumbai, dealt with a departmental appeal against the order of the National Faceless Appeal Centre for Assessment Year 2020–21 concerning disallowance of interest expenditure. The appeal, delayed by 22 days, was admitted after condonation of delay. The dispute centered on the deletion of disallowance of interest expenses amounting to Rs. 47.76 crore. The assessee, a corporate entity engaged in coal-related activities, had borrowed funds from its holding company at an interest rate of 15% and advanced loa...