2021 (6) TMI 1024

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....penses b) Ad hoc disallowance made out of other expenses. 2. The facts relating to the case are stated in brief. The assessee is engaged in the business of manufacturing of alloy steel cast grinding media balls. The assessee filed its return of income for the year under consideration declaring a total income of Rs. 5.09 crores. The AO completed the assessee by making above said disallowances and the same was also upheld by Ld. CIT(A). 3. The first issue relates to disallowance made out of interest expenses. The A.O. noticed that the assessee has advanced a sum of Rs. 87.30 crores to Shri V.P. Yakob and Others for the purpose of purchase of agricultural land. The assessee did not collect any interest from the said advances. Th....

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....s only Rs. 87.30 crores. Accordingly, the Ld. A.R. submitted that the interest disallowance is not called for in the facts of the present case. 5. On the contrary, the Ld. D.R. submitted that the assessee has not proved the nexus between the interest free advances and the business carried on by the assessee. Further, the assessee has accepted the addition before the A.O. and hence, the assessee is precluded from contesting this addition. 6. In the rejoinder, the Ld. A.R. submitted that it is the case of the assessee that it has not accepted for the addition before the A.O. and further, the assessee is willing to furnish an affidavit in this regard. 7. We heard the rival contentions and perused the record. Admittedly, the own funds ....

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....unt of expenses and the disallowance worked out to Rs. 24.23 crores. The Ld. CIT(A) also confirmed the same. 10. The Ld. A.R. submitted that the assessee could not furnish the details, vouchers, etc., before the A.O., since the operations of the company were almost closed. The Ld. A.R. further submitted that the assessee has furnished details of expenses along with sample vouchers as additional evidences and accordingly she prayed that the additional evidences may be admitted and the issue may be restored to the file of the A.O. for examining it afresh. 11. The ld. D.R., on the contrary, strongly objected to the admission of additional evidences. She submitted that the assessee has furnished only ledger account copies of various expen....