2003 (3) TMI 33

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..... advanced to the four subsidiaries is for purpose of business, is basically a question of fact. No substantial question of law does arise for consideration. Otherwise also, the finding of fact of the Tribunal that interest-free loan to its four subsidiaries was not for the purpose of business is not perverse, nor there was any justification to pay huge amount of interest on the borrowings and advan .....

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..... r the Act? Whether the disallowance of Rs. 75,83,860 under section 36(1)(iii) of the 1961 Act is justified on the ground that no direct nexus is proved between the interest-free advances received from M/s. Gillette U.K. Ltd. and interest-free advances given to subsidiary companies when the nexus is not only evident from the bank statements but is also accepted by the Department in their remand re .....

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..... sallowance of Rs. 73,27,616 under section 36(1)(iii) of the 1961 Act is justified on the ground that no direct nexus is proved between the interest-free advances received from M/s. Gillette U.K. Ltd. and interest-free advances given to subsidiary companies when the nexus is not only evident from the bank statements but is also accepted by the Department in their remand report? Whether the learned .....

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..... ,616 in the assessment year 1990-91. The assessee claimed deduction of this interest in these two assessment years on the ground that the assessee wants to have control over another company, i.e., M/s. Sharpedge Ltd., after purchasing its shares. The Tribunal found that it is not the business of the assessee to purchase and sale of the shares. Admittedly, the assessee has paid the huge amount of .....

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..... aw does arise for consideration. Otherwise also, the finding of fact of the Tribunal that interest-free loan to its four subsidiaries was not for the purpose of business is not perverse, nor there was any justification to pay huge amount of interest on the borrowings and advance the loan to its subsidiaries at free of interest. No interference is called for in the order of the Tribunal. Both the .....

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