TMI Blog2010 (10) TMI 863X X X X Extracts X X X X X X X X Extracts X X X X ..... o the total funds – Held that:- Following the judgment of V.M. Salgaocar and Bros. (P) Ltd. (2000 (4) TMI 2 - SUPREME Court) it was held that giving of interest-free loan to any employee was not covered by the provision of disallowance under Section 40A(5) or Section 40(c) of the Income Tax Act, 1961, question referred is answered against the revenue and in favour of the assessee. - I.T.R. Nos. 5 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by allocating the said interest in the proportion as the borrowed funds of the assessee company bear to the total funds?" 2. Learned counsel for the revenue fairly states that the matter is covered against the revenue by judgment of this Court dated 16.9.2008 in Porritts and Spencer (Asia) Ltd. v. CIT [2008] 175 TAXMAN 533 (paras 51-52), wherein following the judgment of the Hon'ble Supreme C ..... X X X X Extracts X X X X X X X X Extracts X X X X
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