9911796707
TMI Blog2021 (5) TMI 356X X X X Extracts X X X X X X X X Extracts X X X X ..... refore, in the case of the assessee we hereby hold that LIBOR rate of interest shall be adopted while computing the notional interest on receivables and payables for the transaction with AEs. Further, on considering the nature of trade of the assessee, we find it appropriate to fix the grace period of 30 days while computing the notional interest towards the debit and credit transaction with the AEs. It is ordered accordingly. Disallowance of club expenditure - AO made the addition stating same was not justified as business expenditure by the assessee in the Form-3CD - HELD THAT:- As before us, the assessee has not substantiated that the expenditure was incurred for the purpose of the assessee's business. Hence, we hereby confi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erred in disallowing the club expenditure amounting to ₹ 2,41,139/- by stating that it is not for the purpose of the business of the assessee. (iii) The Ld. AO has erred in making an ad hoc disallowance of ₹ 10 lakh towards expenditure incurred on freight and ₹ 2 lakhs towards expenditure incurred on repairs. 3. The brief facts of the case are that the assessee is a Private Limited company engaged in the business of manufacturing steel rods filed its return of income on 28/11/2014 admitting total income of ₹ 9,03,08,870/-. Thereafter, the case was taken up for scrutiny and the assessment was completed u/s. 143(3) 144C(13) of the Act on 30/07/2018 wherein the ld. AO made the above mentioned additions. 4. G ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s AEs because when notional interest is charged on receivables the same should also be charged on payables. Therefore, in the case of the assessee we hereby hold that LIBOR rate of interest shall be adopted while computing the notional interest on receivables and payables for the transaction with AEs. Further, on considering the nature of trade of the assessee, we find it appropriate to fix the grace period of 30 days while computing the notional interest towards the debit and credit transaction with the AEs. It is ordered accordingly. 7. Ground No.: 2: Disallowance of club expenditure of ₹ 2,41,139/-: 8. The ld. AO has disallowed the club expenditure incurred for ₹ 2,41,139/- by stating that the same was not justified ..... X X X X Extracts X X X X X X X X Extracts X X X X
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