TMI Blog2015 (10) TMI 2850X X X X Extracts X X X X X X X X Extracts X X X X ..... form interest rate in all the above three categories to be @ 15% resulting in the impugned disallowance - HELD THAT:- We find that the hon ble jurisdictional high court in Sarjan Realities Ltd.[ 2014 (8) TMI 206 - GUJARAT HIGH COURT ] holds that solely because an assessee had paid an interest to different parties would not itself be a ground to come to conclusion that payment of interest to rela ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (A), Gandhinagar dated 28-12-2011 in appeal no. CIT(A)- GNR/176/1011, in proceedings under section 143(3) of the Income Tax Act, 1961; in short the Act . 2. The assessee s sole substantive ground challenges interest disallowance of Rs. 1,33,109/- made by both the authorities below u/s. 40A(2)(b) of the Act after treating the same as excessive. The Assessing Officer noticed in the course of scr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reiterated for the sake brevity. We find that the hon ble jurisdictional high court in (2014) 50 taxmann.com 52 Gujarat CIT Vs. Sarjan Realities Ltd. holds that solely because an assessee had paid an interest to different parties would not itself be a ground to come to conclusion that payment of interest to related companies at rate other than that paid to other parties was excessive and unreason ..... X X X X Extracts X X X X X X X X Extracts X X X X
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