Commercial Expediency Shield

In a combined dispute involving interest disallowance and Section 68 additions, the Tribunal upheld deletion of disallowance on interest-free advances to sister concerns, holding that commercial expediency and availability of own funds negate any presumption of diversion. 

It further sustained deletion of unexplained cash credit additions where identity, genuineness, and creditworthiness were duly established. The ruling reinforces that tax neutrality, business purpose, and evidentiary discharge collectively defeat mechanical additions.