2020 (2) TMI 1545

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....nt Year [in short referred to as 'AY'] 2007-08 contest the order of Ld. Commissioner of IncomeTax (Appeals)-30, Mumbai, [CIT(A)], Appeal No. CIT(A)-30/19(2)/242/15- 16 dated 17/07/2017 qua deletion of certain additions aggregating to Rs. 102.36 Lacs as made by Ld. AO on account of accommodation entries for unsecured loans and interest paid thereupon. 2. The Ld. Authorized Representative for Asses....

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....fore, the same could not be considered as 'external source' as is referred to in para 10(e) of CBDT circular dated 20/08/2018. When CBDT is referring to external sources, it is certainly referring to sources which are not internal sources within the Income Tax Department and various wings functioning within its aegis. It has further been submitted that the subsequent CBDT Circular No. 23 of 2019 d....

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....ated 08/08/2019 issued by Central Board of Direct Taxes [CBDT]. This recent circular further enhances the monetary limit fixed in earlier Circular No.3 of 2018 dated 11/07/2018 issued by CBDT as amended on 20/08/2018. Undisputedly, the factual matrix is not covered by any of the exceptions as provided in para-10 of Circular no. 3 of 2018 dated 11/07/2018. The co-ordinate bench of this Tribunal in ....

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....rt Term Capital Loss (STCL) through penny stocks and do not apply to the cases of accommodation unsecured loans. 6. We have gone through the circulars and find that the tax effect in dispute is below prescribed limit of Rs. 50 Lacs and the assessee stood benefitted by the above circular issued by CBDT wherein the minimum monetary limit for filing the appeals before various appellate authorities h....