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TMI Blog2014 (5) TMI 393X X X X Extracts X X X X X X X X Extracts X X X X ..... iling market rate - they have also assessed to tax (in same tax bracket) and there is no loss of revenue - The CBDT has issued circular on this issue, wherein it has been decided by the Board that no addition should be made where the sister concerns fall in the same tax bracket – revenue has not controverted the findings of the CIT(A) – Decided against Revenue. - ITA No. 207/Ahd/2013 - - - Dated:- 29-4-2014 - Shri D. K. Tyagi And Shri T. R. Meena,JJ. For the Appellant : Shri K. C. Mathews, Sr. D. R. For the Respondent : Shri U. S. Bhati, A.R. ORDER Per : Shri T. R. Meena, Accountant Member This is an appeal at the behest of Revenue which has emanated from the order of CIT(A)-VIII, Ahmedabad, dated 18.10.20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d be seen from the ledger account of interest that interest has been charged at the rate of around 10 to 12 percent. The rate of interest paid is actually less than the rate of interest charged on loans and advances: The reasons for reopening of the assessment on the ground that the appellant has paid average interest at the rate of 12 per cent and charged at the rate of 6.84 per cent, are factually wrong. The appellant has submitted the consolidated table for the interest charged on the advances given and the interest paid on the loan taken as above. The appellant has also submitted the same facts before the AO as the total average borrowing during the year under consideration was above Rs.30 Crores (opening 29.68 + closing 32.17) on whic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s.69.52 crore in preceding year to Rs.114.01 crore in the year under consideration. The assessee has charged interest @ 10% per annum from Apollo Industries Projects Ltd., 9% from Highway Safety Systems Pvt. Ltd. 12% from Circuit Systems (India) Ltd., which has been shown as income by the appellant (page no.46 of paper book). Therefore, the order of CIT(A) may be confirmed. 5. We have heard the rival contentions and perused the material on record. The assessee company has own money in form of share capital, reserve surplus and profit earned during the year. The interest charged from the sister concern as per the prevailing market rate. Further, they have also assessed to tax (in same tax bracket) and there is no loss of revenue. Th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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