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While noting that in the subsequent year the interest cost was allowed in the proceedings completed under section 143(3) the tribunal in (2022] 100 ITR (Trib) 109 (ITAT[Jai] found little justification for the revenue to hold on with a disallowance in the appeal year given that the assessee had sufficient interest-free funds and that the Revenue had not co-related the interest-bearing funds used for non-interest bearing purposes. 

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