Section 36 of Income Tax Act, 1961—Disallowance of interest expenses—In the instant case, revenue disallowed the interest expenses claimed by assessee on the ground that the funds taken on higher rate of interest have been given to sister concerns at lower rate of interest.

Held that—the case law relied upon by the Ld. AR for the assessee is directly applicable in the present case i.e. CIT Vs. S.A. BUILDERS 288 ITR 1 (SC), wherein, it has been held that “If advance was given for commercial expediency then no disallowance for interest can be made.”

Tribunal set aside the orders of the authorities below and delete the addition in dispute allow the grounds raised by the assessee.[BRINDAVAN AGENCIES (P) LTD. VERSUS ACIT, CIRCLE 5 (1) , C.R. BUILDING, NEW DELHI][2019] 10 ITCD Online (40) [ITAT DELHI]