2022 (7) TMI 934

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....g the present appeals, sought to set aside the impugned order even dated 07.12.2021 passed by the National Faceless Appeal Centre (NFAC) [Commissioner of Income Tax (Appeals), Delhi] (hereinafter referred to as CIT(A)] qua the assessment years 2013-14 & 2014-15 on identically worded grounds except the difference in figures inter alia that:- "1.1 Ground of Appeal That on facts and in law the Ld. CIT has erred in confirming an addition to total income of Rs. 16,38,797/- of interest paid on loan. Our Submission 1. Allow the deduction of interest paid of Rs. 16,38,797/- since Commissioner Appeal erred in a. Ignoring relevant material and considerations as submitted by the Appellant - Here Commissione....

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.... Held that Addition on account of Unsecured Loans cannot be made where the Assessee discharges its primary onus of providing complete details in respect of loan transactions. b. In this regard, the Learned Assessing Officer failed to consider the fact that the information/view taken while passing the order is general in nature with no evidentiary value. c. The Learned Assessing Officer failed to consider the fact that the Appellant had furnished the Loan Confirmations, ITR and Bank Statements of Loan Parties. d. Also, the Learned Assessing Officer failed to consider the fact that the Appellant had actually taken loan from the above said parties for its smooth running of the business and the said transaction was ....

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....entries of bogus purchases/unsecured loan and the assessee was one of the beneficiaries who has obtained accommodation entries of unsecured loan. Declining the contentions raised by the assessee, AO proceeded to hold that the alleged loan from M/s. Rajat Diamond Exim P. Ltd. and M/s. Frontline Diamond P. Ltd. of Rs. 2,57,003/- and Rs. 13,81,794/- respectively was non genuine/accommodative in nature and thereby made addition of Rs. 1638797/- (Rs. 2,57,003 + Rs. 13,81,794) and thereby framed the assessment under section 143(3) of the Income Tax Act, 1961 (for short 'the Act'). 3. Assessee carried the matter before the Ld. CIT(A) by way of filing appeal who has confirmed the addition by dismissing the appeal. Feeling aggrieved with ....