2012 (10) TMI 148

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..... Rs.91 lacs towards principal and interest. It is obvious that a part of above amount was towards interest for the OTS amount was admittedly more than Rs.72 lacs (principal amount) - working of the proportionate amount by the assessee is not based on what infact transpired between SICOM and itself. The basis is merely hypothetical. It is not inconceivable that the interest was waived and/or reduced .....

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..... of the case, the allocation of Rs.91,00,000/made by the Appellant between the principal amount and the interest due is correct in law? 3. The appellant had availed a term loan from SICOM. As per its book of accounts an amount of Rs.1,46,63,160/was due and payable in respect thereof. The principal sum was Rs.72 lacs. The interest therefore was Rs.74,63,160/. The appellant entered into a one time .....

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..... s towards interest for the OTS amount was admittedly more than Rs.72 lacs (principal amount). 7. The assessee having failed to produce any documents or other evidence in this regard, we see no reason to speculate in its favour. The working of the proportionate amount by the assessee is not based on what infact transpired between SICOM and itself. The basis is merely hypothetical. It is not incon .....

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