Interest rate on unsecured loan cannot be compared with interest rate on bank loan

R R M Trading Co. Vs ACIT (ITAT Delhi) ITAT find that AO has restricted the payment of interest to the related parties @ 18% to 12% on the ground that it is excessive and unreasonable looking to the fact that assessee has paid interest to the partners @ 12% which is in accordance with the Partnership deed. However, nowhere AO has tried to establish that having regard to the fair market value, such an interest payment is excessive or unreasonable without bringing any comparable instances that unsecured loan in the market are less. Apart from that, we agree with the submission of the ld. Counsel...