9911796707
TMI Blog2004 (6) TMI 303X X X X Extracts X X X X X X X X Extracts X X X X ..... ence. 2. The only point in dispute in both the appeals is with regard to disallowance of interest paid on borrowals were disallowed in view of the interest-free advances made to relatives and friends of the partners of the firm. In asst. yr. 1990-91, the disallowance was Rs. 63,600 and in asst. yr. 1991-92 it was 66,600. The assessee-firm had advanced Rs. 3,20,000 on 1st April, 1989, to Anil Kum ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ctive ground of appeal. All other grounds of appeal are in the arguments only. 3. We have heard the rival submissions and have perused the evidence on record. 4. The learned CIT(A) held that it is settled principle that if a firm has non-interest bearing funds in excess of interest-bearing advances, then also no adverse inference can be drawn. The learned CIT(A) concluded that in this case the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... disallow interest in such cases. 5. The learned CIT(A) has also not decided by passing a speaking order in relation to the claim of the assessee that these loans were not advanced during the period relevant for assessment year under consideration. In the case of one advance and in relation to second advance it was related only for asst. yr. 1990-91. The learned CIT(A) failed to decide these imp ..... X X X X Extracts X X X X X X X X Extracts X X X X
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