2017 (3) TMI 1854

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....in confirming the action of Id. AO in disallowing interest expenditure of Rs. 11,85,430/-. 2. The Id. CIT(A) has confirmed the disallowance by observing that before the assessing officer the Appellant himself unequivocally agreed for the disallowance of interest expenditure by withdrawing submission filed on 20/11/2011, vide order sheet entry dated on 24/11/2011. 3. The Id. CIT(A) ought to have appreciated that the Appellant vide letters dated 20/10/2011 and 20/11/2011 submitted and explained to the Id. AO that the alleged interest free advances is nothing but the business advances provided to the various parties and therefore no disallowance of interest can be made. 4. The Id. CIT(A) ought to have appreciated tha....

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....e action of Id. AO in charging interest u/s 234B/C/D of the Act. 10. The Id. CIT(A) has erred in law and on facts in confirming the action of Id. AO in initiating penalty proceedings u/s 271(l)(c) of the Act." 3. When this appeal was called out for hearing, learned counsel for the assessee submitted that all he prays for at this stage is for the matter being remitted to the Assessing Officer for fresh adjudication on merits. He points out that accountant of the assessee had, under a mistaken impression, signed the proceedings sheet which stated that it is an agreed addition, and, therefore, according to learned counsel, the matter should now be examined on merit. It is also pointed out that the learned CIT(A) has, on the ground ....