2014 (5) TMI 200

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..... oq Irani ORDER P. C. 1. We have heard Mr.Suresh Kumar, appearing on behalf of the Revenue in support of this Appeal. We have perused the order passed by the Assessing Officer and the Commissioner of Income Tax (Appeals). 2. In accepting the Appeal of the assessee and reversing the concurrent orders of the Assessing Officer and the Commissioner of Income Tax (Appeals) for the relevant Assessmen .....

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..... als), it was impossible to reach a conclusion that the amount of Rs.5,46,00,000/was a loan given by the Trust to this Private Limited Company. In fact, it was an advance so as to enable the Trust to acquire an asset. The understanding was that in the event the construction is not ready and complete and the building is not ready, the amount would be returned back to the Trust. In such circumstances .....

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