2021 (5) TMI 965

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....3) (in AY.2010-11) of the Income Tax Act, 1961 [in short, 'the Act']; respectively. Heard Shri S.Rama Rao and Shri Sunil Kumar Pandey, DR, representing assessee and Revenue respectively. 2. It transpires at the outset that the instant batch of five appeals involves almost all identical interconnected issues. The same are therefore taken up for adjudication. 3. Both the learned representatives submitted before us that the assessee's first and foremost identical grievance pleaded in AYs.2006-07 to 2009-10's ground Nos.2 & 3 challenges correctness of both the lower authorities' action treating the corresponding receipts of Rs. 12,98,135/-, Rs. 2,55,916/- and Rs. 45,22,790/-; as income from house property & business income; as the c....

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....fficer to this limited extent only to the extent that whatever is the income assessed as income from other sources in the assessee's hands out of its books/P&L A/c of the corresponding assessment years, shall not be assessed under the head business income as well so as to avoid double addition. It is made clear that it shall be the assessee's risk and responsibility only to file on record all the relevant details proving that the very sums of additions before us have also been assessed under the head income from house property and business income; as the case may be. Needful shall be done within three effective opportunities of hearing. This first issue raised in the assessee's former three substantive grounds in AYs.2006-07, 2007-08, 2008-....

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....at it shall be a risk and responsibility of the assessee only to file its supportive evidence proving live nexus of the impugned sister concern. This second issue also accepted partly for statistical purposes in foregoing terms. The assessee's appeals 294, 295 and 296/Hyd/2013 for AYs.2006-07 to 2008-09; respectively raising the instant twin ground only are partly allowed for statistical purposes in above terms. 5. This leaves us with the assessee's third substantive ground each in ITA Nos.297 and 298/Hyd/2013 for AYs.2009- 10 and 2010-11 seeking to delete interest disallowance(s) of Rs. 19,34,277/- and Rs. 14,55,802/-; respectively. After vehemently arguing some time in support of the assessee's grievance, learned counsel informed....