2017 (10) TMI 1076

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....see, is directed against the order dated 3rd January 2011 passed by the CIT(A), in the matter of assessment under section 144 of the Income Tax Act, 1961, for the assessment year 2006-07. 2. Although the assessee has raised as many as seven grounds of appeal, the only grievance pressed before us, which is required to be adjudicated on merits, is against the learned CIT(A) confirming the disallo....

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....during the relevant financial period- first, of Rs. 11,155 in respect of Nandlal Arvind and Co; - second, of Rs. 1,014 in respect of Shrenikbhai Sheth Mehsana; and- third, of Rs. 14,95,279 in respect of M/s Contracts. The copies of accounts of these persons were duly furnished. It was noted that so far as M/s Contacts was concerned, the assessee had advanced Rs. 5,00,000 in the month of June 1998 ....

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....disallowance on the ground that the advances were not given in the course of business. The assessee is not satisfied and is in further appeal before this Tribunal. 4. I have heard the rival contentions, perused the material on record and duly considered facts of the case in the light of the applicable legal position. 5. I have noticed that entire discussion by the CIT(A) has remained confine....

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...., so far as debits on account of interest charged on the said amount are concerned, as long as assessee can demonstrate that these interest debits, at the time of corresponding credit to interest income, were offered to tax, the assessee will be fully entitled to claim deduction in respect of the write off an income which never fructified. On this aspect of the matter, I deem it fit and proper to ....