2010 (8) TMI 1104

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..... di rected against the order dated 15.10.2009 of CIT(A)-23, Mumbai for the assessment year 2006-07 2. Only effective ground raised by the assessee is as under : "I . .On the facts and in the ci rcumstances of the case learned CIT(A) er red in confirming I n his order disallowance of interest of ₹ 6,88,161/ - as being interest paid related to interest bearing funds utilized for making non-i .....

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..... rns. I t is argued that the said deposits are collected at much lower rates of interest than the prevailing lending rates in the market . He, further, argued that due to the commercial expediency, the assessee firm is constituted exclusively assigning the work of financing the different family concerns to augment the business activities. The Ld Counsel further submitted that the Ld CIT(A) misunder .....

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..... the assessee firm is to give financial support to the group concerns in the 'Bhogilal Family'. The A.O has no reservation in respect of the rate of interest charged by the assessee. I t means that the A.O impliedly accepted that there is nomala fide even on the rates charged by the assessee to the family concerns to which the loans or advances are given. The only reservat ion for the addi t ion ma .....

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