In the result, grounds of appeal raised by the assessee are allowed
Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay
iii. That the provisions of section 194A for deduction of TDS on interest was not applicable in the facts of the case of the assessee since only a notional/hypothetical entry of aforesaid amount of interest was made. The company was continuously running in loss and was under BIFR for declaration of sick company. M/s OIL, parent company of the appellant