2014 (2) TMI 1357

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....er concern without commercial expediency. 2. On the facts and circumstances of the case, the Ld. CIT (A) has erred in deleting disallowance of Rs. 7,00,000/- being notional rental income calculated u/s 23 of the Income Tax Act,1961. 3. On the facts and on the circumstances of the case, the Ld. CIT (A) has erred in admitting the additional evidence before her without affording any opportunity to Assessing Officer for examine the evidence as per Sub-Rule 46A of the IT Rules 1962. 4. The appellant craves leave to add, alter or amend any of the grounds of appeal before or during the course of hearing of the appeal." 2. We have heard Ms. Y. Kakkar Ld. Departmental Representative on behalf of the Revenue and Mr.V.S.Gupta, Ld. Advocate ....

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....interest free funds. Presumption is that such interest free funds have been utilized for giving interest free advances, unless otherwise proved. For this proposition we draw strength from the judgment of the Hon'ble Bombay High Court in the case of CIT vs. Reliance Utilities and Power Ltd., 313 ITR 340 (Bom). Respectfully following the same we uphold the finding of the Ld. CIT (A). 6. The Ld. CIT (A) also held that the loans in question taken by the assessee were for specific purposes, namely for export bill discounting, packing credit loans, term loan taken for purchase of property for business use, car loan and overdraft. The Bank when guaranty such specific loans, ensure that the money is used for the purpose for which it is given . Th....