TaxTMI 
TaxTMI 
2021 (6) TMI 56
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.... u/s 263 of the Act in respect of loans received by the assessee which were also squared up by the assessee, in the facts and circumstances of the case. 3. We have heard the rival submissions and perused the materials available on record. We find that the assessee is a partnership firm engaged in the business of manufacturing and selling of Polyurethane Flexipuff Foam and also providing services like finding market course in their field or providing commission basis services to their customers. We find that the assessee had filed its return of income for the Asst Year 2015-16 on 31.10.2015 declaring total income of Rs. 63,88,660/-. The assessment for the Asst Year 2015-16 was completed u/s 144 of the Act on 8.12.2017 determining total inco....
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....e assessee in response to show cause notice issued u/s 263 of the Act had responded before the ld PCIT that it had received a fresh loan from Shri Nilesh Patel during the year under consideration of Rs. 11,30,000/- and the same was not squared up during the year. It was specifically pointed out before the ld PCIT that a sum of Rs. 30,38,000/- was outstanding at the end of the year. It was also pointed out that the receipt of the said loan in the sum of Rs. 11,30,000/- was duly disclosed in the tax audit report of the assessee and it was also mentioned that the said loan was not squared up during the year. It was specifically pointed out before the ld AO that only two loans in the sums of Rs. 5,45,33,400/- were squared up during the year and....