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TMI Blog2013 (1) TMI 804X X X X Extracts X X X X X X X X Extracts X X X X ..... d Deletion of addition being interest receivable on outstanding amount - Held that:- interest income is associated only with the lending or borrowing of money and not in case of sale - the specific finding of the ITAT is that there is complete uniformity in the act of the assessee in not charging interest from both the Associated Enterprises and Non Associated Enterprises debtors and the delay ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n law the ITAT was justified in deleting the addition of ₹ 87,66,641/being interest receivable on outstanding amount due to the Assessee Company from the Associated Enterprises? 2. As regard the first question is concerned, Counsel for the parties state that similar question raised by the Revenue in the Assessee's own case being Income Tax Appeal No. 6869 of 2010 has been rejected by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lance amount of ₹ 3.62 Crores was outstanding from non Associated Enterprises. Relying on the Board Circular no. 12 of 2001, the CIT(A) further held that in the present case, the profit of one Associated Enterprise is negligible and the other Associated Enterprise has incurred losses and therefore it cannot be said that the assessee had transfered any profit to the Associated Enterprises out ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y in realisation of the export proceeds in both the cases is same. In these circumstances the decision of the Tribunal in deleting the notional interest on outstanding amount of export proceeds realised belatedly cannot be faulted. 6. Accordingly, we see no reason to entertain the second question raised by the revenue. 7. The Appeal is accordingly dismissed with no order as to costs. - - ..... X X X X Extracts X X X X X X X X Extracts X X X X
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