9911796707
TMI Blog2020 (11) TMI 810X X X X Extracts X X X X X X X X Extracts X X X X ..... apital advances at year end stood at ₹ 20.23 Crores as against opening balance of ₹ 19.83 Crores which would show that there was only a marginal increase of ₹ 40 Lacs during the year. Further, the interest-bearing secured loans obtained by the assessee were meant only for specific purposes i.e. packing credit or post-shipment credit. It could very well be concluded that there was no nexus of borrowed funds with the capital advances made by the assessee and the assessee had sufficient own funds to make the aforesaid investments. Without establishing any direct nexus of borrowed funds vis- -vis capital advances, no such disallowance could have been made by revenue authorities. Thus interest disallowance is not sustainable ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... investments under consideration. The Ld. DR, on the other hand, controverted the submissions by stating that facts are different in this year. It has been submitted that the assessee did not file any fund flow statements in support of the submissions that own funds were used to make the investments in certain premises, against which the disallowance has been computed by lower authorities. 3. We have carefully considered the rival submissions and perused relevant material on record including orders of lower authorities, assessee s financial statements for the year under consideration as well as the cited order of Tribunal in assessee s own case for AY 2009-10 which has been co-authored by one of us. Our adjudication to the subject matt ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... light of his adjudication in AY 2013-14. Aggrieved, the assessee is under further appeal before us. 6. The perusal of assessee s financial statements would show that the assessee has own funds in the shape of share capital reserves aggregating to ₹ 225.28 Crores at year end as against opening funds of ₹ 153.15 Crores. Besides the above funds, the assessee has interest free unsecured loans of ₹ 58.72 Crores at its disposal at year end. As against this, the capital advances at year end stood at ₹ 20.23 Crores as against opening balance of ₹ 19.83 Crores which would show that there was only a marginal increase of ₹ 40 Lacs during the year. Further, the interest-bearing secured loans obtained by the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X
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