SANJIV KHANNA, J.

This appeal by the Revenue in the case of DLF Hotel Holding Limited (“respondent-assessee” for short) arises from the order dated 9th April, 2018 of the Income Tax Appellate Tribunal in ITA No. 1750/DEL/2015 and pertains to the Assessment Year 2010-11.

2. The facts in brief are that during the period relating to the Assessment Year 2010-11 an addition of Rs.83,63,03,480/- was made to the opening balance of the paid up share capital of the respondent-assessee, enhancing the same to Rs.1259,68,00,000/-. The respondent-assessee had invested Rs.1165,23,06,015/- in shares of group companies. The respondent-assessee had also taken unsecured loans of Rs. 223,10,02,165/- on which interest of Rs. 12,83,76,153/- was paid and claimed as a deduction under Section 36(1)(iii) of the Income Tax Act, 1961 (the Act, for short). The respondent-assessee had also given unsecured loans of Rs. 205,20,21,046/- to subsidiary companies. The respondent-assessee had received Rs. 12,83,76,153/- as interest on unsecured loans given to the subsidiary companies and others, which was