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“interest free advances”

DisallowancesSection 36(1)(iii)Section 36(1)(iii)565 judgments

ARIMILLI RAMA KRISHNA,WEST GODAVARI DIST vs. ACIT, CIRCLE-1, RAJAHMUNDRY

ITA 639/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam18 Mar 2026AY 2014-15

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 194CSection 194JSection 2(22)(e)Section 263

personal properties as collateral to the bank and also given personal guarantee for availing credit facilities for the company. Further he had given interest free advances to the company of Rs. 2 crores. In view of the same it has been claimed that when he was in need of some

BOMBAY MINERALS LIMITED,KHAMBHALIA vs. DCIT, CENTRAL CIRCLE 3(3), MUMBAI

In the result, appeal of the Revenue

ITA 5410/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Gaurang R. Sanghavi (Virtually appeared)
Section 143(3)Section 14ASection 36(1)(iii)

assessee to interest on est on borrowed funds calculated borrowed funds calculated at the rate of 12.5% corresponding to corresponding to interest free advances, which comes to which comes to Rs.43,86,610/-, be disallowed. The Ld. CIT(A) after considering the be disallowed. The Ld. CIT(A) after considering ... made by the appellant. As is evident from the y the appellant. As is evident from the submissions placed on record that the interest free advances given submissions placed on record that the interest free advances given submissions placed on record that the interest free advances given by the appellant

DY. COMMISSIONER OF INCOME TAX, CENTRAL CICLE-3(3), MUMBAI, MUMBAI vs. BOMBAY MINERALS LIMITED, GUJARAT

In the result, appeal of the Revenue

ITA 5409/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Gaurang R. Sanghavi (Virtually appeared)
Section 143(3)Section 14ASection 36(1)(iii)

assessee to interest on est on borrowed funds calculated borrowed funds calculated at the rate of 12.5% corresponding to corresponding to interest free advances, which comes to which comes to Rs.43,86,610/-, be disallowed. The Ld. CIT(A) after considering the be disallowed. The Ld. CIT(A) after considering ... made by the appellant. As is evident from the y the appellant. As is evident from the submissions placed on record that the interest free advances given submissions placed on record that the interest free advances given submissions placed on record that the interest free advances given by the appellant

BOMBAY MINERALS LIMITED,KHAMBHALIYA vs. DCIT, CENTRAL CIRCLE 3(3), MUMBAI

In the result, appeal of the Revenue for AY 2016-17 is\ndismissed whereas appeal of the assessee for AY 2016-17 is partly\nallowed and appeal for AY 2018-19 is dismissed

ITA 5408/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17
Section 143(3)Section 14ASection 35Section 35(1)(i)Section 36(1)(iii)

borrowed funds and therefore, he called upon to the\nassessee to interest on borrowed funds calculated at the rate of\n12.5% corresponding to interest free advances, which comes to\nRs.43,86,610/-, be disallowed. The Ld. CIT(A) after considering the\nfacts and circumstances of the case and relying ... contentions of the AO and the\nsubmissions made by the appellant. As is evident from the\nsubmissions placed on record that the interest free advances given\nby the appellant to PCL originated in the FY 2000-01 and it was from\nFY 2007-08 that PCL came to owe money

NIPUN MALHOTRA,MANDI vs. ITO, WARD, MANDI

In the result, appeal of the assessee is allowed

ITA 81/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh20 Feb 2026AY 2013-14

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 81/Chd/2022 "नधा"रण वष" / Assessment Year: 2013-14 Nipun Malhotra, The Ito, 135/A, Jawahar Nagar, Vs Ward, Mandi, Himachal Pradesh. Mandi (Hp). "थायी लेखा सं./Pan No: Ablpm6589N अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ajay Jain, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 12.02.2026 Date Of Pronouncement : 20.02.2026 Physical Hearing O R D E R

For Appellant: Shri Ajay Jain, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR
Section 143(3)Section 263

advances given to individuals and certain concerns. In the opinion of the A.Y.2013-14 3 AO, assessee has used interest bearing funds for making interest free advances. 3.1 The assessee has filed copy of the balance sheet as on 31.03.2013 on page Nos. 2 to 5 of the Paper Book ... present is that if assessee has mixed funds and it has more interest free funds, then it is to be assumed that interest free advances were given out of interest free funds available with the assessee. For buttressing this proposition, we take note of the following judgements : a) ACIT

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 4321/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

ground is in respect of disallowance of interest. Contention of ld. Assessing Officer is that assessee has used its interest bearing funds for interest free advances and charged lesser interest rate. By taking this view, he made a disallowance of proportionate interest of Rs.5,81,28,099/-. 6.4. Fact

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 4320/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

ground is in respect of disallowance of interest. Contention of ld. Assessing Officer is that assessee has used its interest bearing funds for interest free advances and charged lesser interest rate. By taking this view, he made a disallowance of proportionate interest of Rs.5,81,28,099/-. 6.4. Fact

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 4319/MUM/2025[2019-20]Status: DisposedITAT Mumbai20 Feb 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

ground is in respect of disallowance of interest. Contention of ld. Assessing Officer is that assessee has used its interest bearing funds for interest free advances and charged lesser interest rate. By taking this view, he made a disallowance of proportionate interest of Rs.5,81,28,099/-. 6.4. Fact

ACIT, CC-6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 4318/MUM/2025[2022-23]Status: DisposedITAT Mumbai20 Feb 2026AY 2022-23

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

ground is in respect of disallowance of interest. Contention of ld. Assessing Officer is that assessee has used its interest bearing funds for interest free advances and charged lesser interest rate. By taking this view, he made a disallowance of proportionate interest of Rs.5,81,28,099/-. 6.4. Fact

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

ITA 4090/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

ground is in respect of disallowance of interest.\nContention of ld. Assessing Officer is that assessee has used its interest\nbearing funds for interest free advances and charged lesser interest\nrate. By taking this view, he made a disallowance of proportionate\ninterest of Rs.5,81,28,099/-.\n6.4. Fact

OVERSEAS INFRASTRUCTURE ALLIANCE(INDIA) PRIVATE LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI

ITA 4064/MUM/2025[2022-23]Status: DisposedITAT Mumbai20 Feb 2026AY 2022-23

ground is in respect of disallowance of interest. Contention of ld. Assessing Officer is that assessee has used its interest\nbearing funds for interest free advances and charged lesser interest\nrate. By taking this view, he made a disallowance of proportionate\ninterest of Rs.5,81,28,099/-.\n6.4. Fact

OVERSEAS INFRASTRUCTURE ALLIANCE(INDIA) PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -6 , MUMBAI

In the result, appeal by the assessee is allowed

ITA 4045/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

ground is in respect of disallowance of interest. Contention of ld. Assessing Officer is that assessee has used its interest bearing funds for interest free advances and charged lesser interest rate. By taking this view, he made a disallowance of proportionate interest of Rs.5,81,28,099/-. 6.4. Fact

OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMTIED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI

In the result, appeal by the assessee is allowed

ITA 4044/MUM/2025[2021-22]Status: DisposedITAT Mumbai20 Feb 2026AY 2021-22

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

ground is in respect of disallowance of interest. Contention of ld. Assessing Officer is that assessee has used its interest bearing funds for interest free advances and charged lesser interest rate. By taking this view, he made a disallowance of proportionate interest of Rs.5,81,28,099/-. 6.4. Fact

OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMTIED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI

In the result, appeal by the assessee is allowed

ITA 4043/MUM/2025[2019-20]Status: DisposedITAT Mumbai20 Feb 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

ground is in respect of disallowance of interest. Contention of ld. Assessing Officer is that assessee has used its interest bearing funds for interest free advances and charged lesser interest rate. By taking this view, he made a disallowance of proportionate interest of Rs.5,81,28,099/-. 6.4. Fact

ACIT CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 3998/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

ground is in respect of disallowance of interest. Contention of ld. Assessing Officer is that assessee has used its interest bearing funds for interest free advances and charged lesser interest rate. By taking this view, he made a disallowance of proportionate interest of Rs.5,81,28,099/-. 6.4. Fact

ACIT, CC-6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

ITA 3995/MUM/2025[2011-12]Status: DisposedITAT Mumbai20 Feb 2026AY 2011-12

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

ground is in respect of disallowance of interest. Contention of ld. Assessing Officer is that assessee has used its interest bearing funds for interest free advances and charged lesser interest rate. By taking this view, he made a disallowance of proportionate interest of Rs.5,81,28,099/-. 6.4. Fact

INCOME TAX OFFICER, CHENNAI vs. AVIGNA PRIVATE LIMITED, CHENNAI

In the result, the appeal of the revenue is allowed for statistical purposes

ITA 2930/CHNY/2025[2023-24]Status: DisposedITAT Chennai13 Feb 2026AY 2023-24

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2930/Chny/2025 िनधा$रण वष$ /Assessment Year: 2023-24

For Appellant: Mr. M. Karunakaran, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT
Section 250Section 36(1)(iii)Section 40

year was approximately equivalent to the increase in loans and advances to subsidiaries, establishing a clear nexus between the borrowed funds and the interest-free advances. 8. For these and other grounds that may be adduced at the time of hearing, it is prayed that the order of the learned ... supply with fully closed proper compound wall and security gates and carry on construction of large scale warehouses Cum Logistics parks. Therefore, such interest free advances made to wholly owned subsidiary companies to create largest land bank for the exclusive use and purpose of the facilitating appellant holding Avigna

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. IL & FS ENGINEERING & CONSTRUCTIONS CO. LIMITED , HYDERABAD

ITA 129/HYD/2020[2008-09]Status: DisposedITAT Hyderabad11 Feb 2026AY 2008-09
Section 139(5)Section 194ASection 194CSection 37Section 40Section 40A(3)Section 69C

{ "clean_text": "2\nITA Nos. 129/Hyd/2020 & 1886/Hyd/2019\nIL & FS Engineering & Constructions Co.Ltd.\nORDER\nPER MANJUNATHA G., A.M :\nThe captioned appeals

IL & FS ENGINEERING AND CONSTRUCTION COMPANY LIMITED(FORMERLY MAYTAS INFRA LIMITED),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-9, HYDERABAD

ITA 1886/HYD/2019[2008-09]Status: DisposedITAT Hyderabad11 Feb 2026AY 2008-09
Section 139(5)Section 194ASection 194CSection 37Section 40Section 40A(3)Section 69C

{ "clean_text": "2\nITA Nos. 129/Hyd/2020 & 1886/Hyd/2019\nIL & FS Engineering & Constructions Co.Ltd.\nORDER\nPER MANJUNATHA G., A.M :\nThe captioned appeals

RITURAJ STEEL PRIVATE LIMITED,BILASPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1), BILASPUR

In the result, the appeal of assessee is allowed for statistical purposes

ITA 697/RPR/2025[2017-18]Status: DisposedITAT Raipur09 Feb 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 697/Rpr/2025 (िनधा"रण वष" Assessment Year: 2017-18) Rituraj Steel Private Limited, M/S Vs Assistant Commissioner Of Income Rituraj Steel Private Limited, Hotel Tax, Circle 2(1), Bilaspur, East Park Agrasen Chowk, Shri Ram Plaza Vapar Vihar, Bilaspur, Chhattisgarh, 495001 Bilaspur, Chhattisgarh, 495001 Pan: Aaccr7589J (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : None (Petition Filed) राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 05/02/2026 घोषणा की तारीख / Date Of : 09/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2017-18 Filed By The Assessee Is Directed Against The Order Dated 29.10.2025 Of The Additional Commissioner Of Income Tax (Appeals), Mysore [‘Addl. Cit(A)’] Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: None (Petition filed)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 250Section 36(1)(iii)

have heard the Ld. Sr. DR at length and have perused the material available on the record. As per the assessee, the interest free advances have been made out of the capital and interest free funds; hence, no disallowance on this score is called for. Whereas the stand of Revenue

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