part of the money so borrowed was advanced to its sister concerns free of interest. The sister concerns are All Steel and Asian Industries ... extent it was payable on the moneys borrowed and diverted to sister concerns free of interest was disallowed in those years.
3. For the year
information revealed that almost the entire interest was
received from their sister-concerns. A paltry amount of Rs.1,849/- was
received on account ... assessee's export business was invested elsewhere viz.
with the sister-concerns and the applicant earned interest income on
such investment.
6. Mr. Pardiwalla
However, the management offered to accommodate them in its sister concern from 1-7-1986 at the same salary which was being paid to them ... clear that, if the workmen did not wish to join the sister concern, their services would be retrenched w.e.f. 30-6-1986. According
Manging Director of the respondent-Company as well as of its sister concern namely Britto Amusement Pvt. Ltd.
4. By agreement dated ... from the date the respondent shifted the said Casino. The said sister concern of the respondent i.e. M/s. Britto Amusements
follows:
i. Advances were made by a company to a sister concern
and adjusted against the dues for job work done by the sister
concern ... floating security deposit was given by a company to its
sister concern against the use of electricity generators belonging
to the sister concern. The company
crores as on 31.03.2009 to associate and
sister concerns without charging any interest. Similarly an amount
of Rs. 1 Crore as on 31.03.2009 was advanced ... sister
concern and associate concern have been made by utilizing its own funds
and there are no borrowed capital that was advanced to sister concern
crores as on 31.03.2009 to associate and
sister concerns without charging any interest. Similarly an amount
of Rs. 1 Crore as on 31.03.2009 was advanced ... sister
concern and associate concern have been made by utilizing its own funds
and there are no borrowed capital that was advanced to sister concern
Tribunal was justified in comparing and
adopting net profit margin of sister concern Pragati Aroma
Oil Distillers Pvt. Ltd. (as existed during the relevant
Assessment ... sales i.e. at
the profit earned/disclosed by the sister concern Pragati Aroma Oil
Distillers Pvt. Ltd. (as existed during the relevant AY), having
that since the
assessee had diverted its borrowed funds to a sister concern
without charging any interest, proportionate interest relating to
the said amount ... fund from the bank and lent some of it to
its sister concern (a subsidiary) on interest free loan.
The test, in our opinion
part of loan secured from
Citibank for lending advances to its sister concerns. The
Assessee had therefore set off the interest expenditure on
monies borrowed ... from Citibank against the interest income
from funds lend to sister concerns.
3) The Assessment Officer while completing the
assessment under Section
