JUDGMENT

Sanjiv Khanna, J. (Oral)--This appeal by the Revenue under Section 260A of the Income Tax Act, 1961, in the case of Reebok India Company relates to the Assessment Year 2011-12 and arises from the order of the Income Tax Appellate Tribunal (Tribunal, for short) in ITA No. 954/Del/2016.

2. The present appeal raises only one question/issue which relates to disallowance of part interest paid on unsecured loans of Rs.502.69 crores as the respondent-assessee had advanced Rs.172.59 crores to third parties on which no interest was charged and received. The Assessing Officer had accordingly proportionately disallowed an amount of Rs.23.60 crore from the interest of Rs.68.75 crores/- paid by the respondent-assessee.

3. Learned counsel for the Revenue has drawn our attention to the order passed by the Assessing Officer which refers to the letter dated 10th March, 2015 written by the assessee to the Assessing Officer providing details of 50 top parties to whom advances had been made/extended. It was stated that the advances were made on account of purely commercial reasons and business exigencies and were recoverable from such parties.

4. The Dispute Resolution Panel had affirme