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2025 Supreme(Online)(ITAT) 11774

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SUJAN LUXURY HOSPITALITY P.LTD NEW DELHI – Appellant
Versus
ACIT CIRCLE-24(2) NEW DELHI – Respondent


ORDER

PER BRAJESH KUMAR SINGH, AM,

This appeal filed by the assessee is directed against the order dated 28.01.2019 of the ld. CIT(A)-16, New Delhi, arising out of order u/s 143(3) of the Income Tax Act, 1961 (hereinafter referred to ‘the Act’) dated 16.03.2016 relating to Assessment Year 2013-14.

2. Brief facts of the case:- The Assessing Officer noted that the assessee had claimed interest expenditure on inter corporate deposit amounting to Rs.24,53,696/-. The Assessing Officer further noted that the assessee during the year had advanced interest free loans to its three associate concerns and had not charged any interest on such advances. The Assessing Officer asked the assessee to explain why interest debited in the profit & loss account amounting to Rs.24,53,696/- being expenditure not directly related for the enhancement of business income should not be disallowed. In reply assessee submitted as follows;

In this regard, it is respectfully submitted that such interest free ICDs to subsidiaries, also engaged in the business of hospitality and being in a financial losses were given in order to fund/support the business venture and strategic investments of the company: owning to our b

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