Tribunal partially allows appeal, remits Section 14A issue, dismisses Sections 153A, 234B, 234C grounds.

The Tribunal partially allowed the appeal by deleting the disallowance of interest expenses and the addition of unaccounted sales consideration. The issue of disallowance under Section 14A was remitted back to the AO for proper determination. Grounds regarding the non-issue of notice under Section 153A and levy of interest under Sections 234B and 234C were dismissed as they were not pressed by the assessee.

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Issues Involved:
1. Disallowance of interest expenses.
2. Addition under Section 14A.
3. Addition of unaccounted sales consideration.
4. Non-issue of notice under section 153A.
5. Levy of interest under sections 234B and 234C.

Detailed Analysis:

1. Disallowance of Interest Expenses:
The assessee claimed interest expenses of Rs. 11,98,032/- against interest income of Rs. 49,50,210/- under section 57(iii) of the Income Tax Act, 1961. The AO disallowed the interest expenditure, stating that the assessee failed to prove it was incurred wholly and exclusively for earning the interest income. The assessee argued that the interest was incurred to arrange funds for lending to M/s Supreme Mega Constructions LLP at a higher interest rate. The CIT(A) partially allowed the appeal, directing the AO to verify the nexus between the borrowings and the investment in FDRs. The Tribunal found that the assessee had made genuine efforts to arrange funds, and the interest expenditure should be considered as incurred in the course of earning interest income. Therefore, the disallowance of interest expenditure was deleted.

2. Addition under Section 14A:
The AO disallowed Rs. 6,80,760/- under section 14A read with Rule 8D(2)(iii), attributing administrative expenses to the earning of exempt income (dividend). The assessee argued that no administrative expenses were incurred for earning the exempt income. The CIT(A) upheld the AO's decision, stating that some administrative expenses were definitely attributable to earning the dividend income. The Tribunal directed the AO to recalculate the disallowance by excluding investments that did not earn exempt income and compare it with 31% of the actual administrative expenses incurred. The issue was remitted back to the AO for proper determination.

3. Addition of Unaccounted Sales Consideration:
During a search in the case of Bliss GVS Pharmaceutical Group, certain loose papers (hundies) were found indicating unaccounted cash transactions involving M/s Growmore Investment and Developers Pvt. Ltd. The AO added Rs. 75 lakhs to the assessee's income, being 50% of the alleged unaccounted cash consideration received for the sale of property. The assessee argued that no such cash was received, and the transactions were misrepresented by an employee of Bliss GVS Pharma Ltd. The CIT(A) upheld the addition, relying on the seized documents and statements made during the search. The Tribunal found no cogent material linking the assessee directly to the receipt of cash and deleted the addition, stating that the AO's conclusion was based on presumptions and assumptions.

4. Non-issue of Notice under Section 153A:
This ground was not pressed by the assessee and was dismissed.

5. Levy of Interest under Sections 234B and 234C:
This ground was not pressed by the assessee and was dismissed.

Conclusion:
The Tribunal allowed the appeal partly, deleting the disallowance of interest expenses and the addition of unaccounted sales consideration, while remitting the issue of disallowance under Section 14A back to the AO for proper determination. Grounds regarding the non-issue of notice under Section 153A and levy of interest under Sections 234B and 234C were dismissed as they were not pressed by the assessee.

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