https://www.taxtmi.com/highlights?id=62359 Disallowing interest u/s. 36(1)(iii) - CIT(A) allowed the claim - AO is drawing adverse inference that assessee has not submitted the utilization of the overdraft in the earlier years. We note that this is not the case, where AO has any power to reopen the case of earlier years or that the AO has stepped into the shoes of ld. CIT and is exercising jurisdiction u/s 263 and that also for earlier year. No cogent rebuttal has been given on behalf of the revenue against the finding given by ld. - AT en-us Wed, 09 Mar 2022 12:39:33 +0530 Wed, 09 Mar 2022 12:39:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=62359 Disallowing interest u/s. 36(1)(iii) - CIT(A) allowed the claim - AO is drawing adverse inference that assessee has not submitted the utilization of the overdraft in the earlier years. We note that this is not the case, where AO has any power to reopen the case of earlier years or that the AO has stepped into the shoes of ld. CIT and is exercising jurisdiction u/s 263 and that also for earlier year. No cogent rebuttal has been given on behalf of the revenue against the finding given by ld. - AT Highlights Income Tax Wed, 09 Mar 2022 12:39:33 +0530 https://www.taxtmi.com/highlights?id=62359