
Section 36(1)(iii) IT Act | Commercial Expediency Validates Interest-Free Advances to Subsidiaries: ITAT Delhi Upholds Deletion of Notional Interest Addition
ITAT Delhi rules that interest-free advances to wholly owned subsidiaries are justified under commercial expediency, rejecting Revenue's notional interest addition. The tribunal also deleted ad-hoc disallowances, emphasizing documentary evidence over presumptive additions, reinforcing tax treatment of intra-group transactions.



