2020 (9) TMI 291

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....iled his return of income for the assessment year (AY) 2014-15 on 31.03.2015 declaring income of Rs. 26,84,400/- and agricultural income of Rs. 9,03,306/-. Assessment u/s 143(3) was completed by the Assessing Officer (AO) on 30.10.2016 determining the income at Rs. 27,14,237/-. The Pr. CIT, on perusal of records observed that the assessee has received unsecured loan of Rs. 6,56,48,896/- from various parties and paid interest thereon of Rs. 1,44,59,214/-, whereas no details of tax deducted at source (TDS) on such interest expenses u/s 194A r.w.s. 40(a)(i) are shown in the audit report. In response to the show-cause notice issued u/s 263 of the Act, the assessee filed a reply dated 22.03.2019. However, the Pr. CIT was not convinced with th....

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..... We have heard the rival submissions and perused the relevant materials on record. The reasons for our decisions are given below. As per the capital account as at 31.03.2014, the appellant has earned total receipts of Rs. 1,03,59,083/- (Rs. 2,46,40,357/- minus opening balance of Rs. 1,42,81,274/-). It consists of remuneration (Rs. 14,71,942/-), interest on capital(Rs. 11,18,263/-), agricultural income (Rs. 9,03,306/-), bank interest (Rs. 9,654/-) , dividend (Rs. 1,703/-) share of profit (Rs. 8,05,577/-), dividend bank (Rs. 60,000/-), interest income (Rs. 54,32,777/-) and other income (Rs. 5,55,860/-). The provisions of section 194A were amended from June 1, 2002 to provide that an individual or a Hindu Divided Family, whose total sales,....