2010 (9) TMI 1221

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..... eting the additions made by the Assessing Officer under Section 56(2)(v) of the Income Tax Act. The Tribunal has taken into account the facts and circumstances of the case and after appreciation thereof, recorded a finding of fact in paragraph No.14, which reads as under: 14. In the end, we would like to emphasise on the fact that several commercial considerations prevail in the business world .....

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..... ence, in our view, the interpretation of Section 56(2)(v) made by the Revenue Authorities is not at all valid and justified. Accordingly, we hold that a transaction of loan can be without interest and a transaction of loan implies an agreement to repay the money i.e. borrowed which also gives reply to the Revenue s query regarding existence of the obligation to repay the money at the time of takin .....

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