2005 (7) TMI 319

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 2. Ground 1(i) deals with the confirmation of addition of Rs. 1,500 out of vehicle and travelling expenses. 3. Out of the total expenses to the tune of Rs. 7,000 and odd, the AO made addition of Rs. 1,500 as the expenses were not properly vouched and the element of personal use out of travelling and vehicle expenses could not be ruled out. The learned CIT(A) confirmed the action. In my conside....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....s observed that the land and building shown by the assessee on the asset side of the balance sheet at Rs. 10,96,795 was his personal asset. The assessee had only shown credit balance of his capital of Rs. 2,84,158. In this way, it was noticed that the assessee had total debit balance of his capital of Rs. 8,12,637 (Rs. 10,96,795 minus Rs. 2,84,158). It was, therefore, opined that the assessee had ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....allowance of interest was either made in that year or in the succeeding year. It was, therefore, urged that no disallowance was warranted in this year as well. It was also submitted that even if the expenditure on interest was held to be not allowable against business income, still the assessee would be entitled to claim of deduction under s. 24 of the Act because the amount was borrowed for acqui....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....isallowance of interest when transaction took place in such earlier years and no disallowance of interest was made in the earlier years. I find force in this submission of the learned Authorised Representative as it has been held in CIT vs. Sridev Enterprises (1991) 97 CTR (Kar) 80 : (1991) 192 ITR 165 (Kar) that no disallowance of interest to the extent of opening capital balance can be made wher....