2011 (4) TMI 1458

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....) The appeal filed by the assessee is directed against the order passed by the ld. CIT(A) on 1.11.2010, on the following grounds: "1 The ld. CIT(A) has erred in sustaining the addition of ₹ 6,00,000/- as notional interest on advance of ₹ 25 lacs each to Shri Ashok Anand and Mrs. Rani Anand, being in violation of Sec 36(iii) of Income-tax Act. The addition be deleted." "2 The ld. C....

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....osition that the amount was advanced for acquisition of new asset which was claimed to be for the furtherance of the business activity of the assessee before us. Admittedly the amount was not advanced as a loan and we find no merit in the orders of authorities below in applying the ratio laid by the Hon'ble Punjab & Haryana High Court in the case of Abhishek Industries (supra). However admitte....

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....assessee submitted that the assessee had running an account with National Fertiliser Ltd. He fairly stated that there were differences in the balances appearing in books viz-a-viz those books of National Fertilisers Ltd. The assessee wants to conceal the aforesaid differences. In this view of the matter, the issue is restored to the file of AO. The assessee is directed to reconcile the difference ....