Investment vs. Loan Dispute: ITAT Partially Allows Appeal, Deletes Interest Expense Disallowance and Directs Specific Tax Treatment

ITAT partially allowed the appeal, holding that the transaction with Kamineni Health Care Pvt. Ltd. was an investment, not a loan, thereby deleting the disallowance of interest expenses. For the loan to United Steel Allied Ind Private Limited, the Tribunal upheld the CIT(A)'s view, directing the AO to levy interest for the actual loan period. The Tribunal found the assessee failed to substantiate claims of commercial exigency or business connection between the companies, thus treating the advances as loans under section 36(1)(iii) of the Income Tax Act. The appeal was consequently partly allowed with specific directions to the Assessing Officer. .....

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