Deduction under s 36(1)(iii)

Interest on Borrowed Capital is not allowable under s 36(1)(iii) where the loan is given to the sister concern without any commercial expediency and no interest is charged on such loan — as held by PHHC in CIT v Varinder Agro Chemicals Limited and Others — In favour of: The revenue

Reassessment — The disclosure of material facts falling within the scope of proviso to s 147 does not include the disclosure on the production of the account book before the Assessing Officer (AO) from which material evidence with due diligence could have been discovered by the AO.

Decided on: 14 October 2011.