2022 (9) TMI 282

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....the ld. Commissioner of Income Tax (Appeals) is erroneous and bad in law. ii. That the ld. Commissioner of Income Tax (Appeals) erred in upholding the adhoc estimated addition on account of national interest on loans and advances given by the company. iii. That the ld. Commissioner of Income Tax (Appeals) erred in upholding the adhoc addition of 72,500/- on shares trading of Rs. 72,50,000/-. vi. That the appellant craves to add or alter any grounds of appeal during the proceedings of appeal." 2. At the time of hearing registry has informed that there is a delay of 45 days of the instant appeal. In this regard, an application has been filed by the assessee stating that due to illness of the director, the instant....

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.... and closing balance is Rs.1,85,00,000/- i.e. average loan/advances is Rs.1,75,25,000/- . In absence of any clarification from the assessee in responses to this office show cause estimated profit of the assessee from the above loan/advances is taken as 10% of the loan/advances which comes to Rs.17,52,500/-. Therefore, Rs.17,52,500/- as added back to the total income of the assessee as undisclosed profit from investment. [Addition: Rs.17,52,500/-] Penalty proceeding u/s270A is initiated separately for under reporting of income. Till date the assessee unable to explain why disallowance u/s.14A will not be invoked in his case. Therefore expenses of Rs.25,709/- is disallowed u/s. 14A and added back to the total income....

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....is initiated separately for under reporting of income. On the basis of the above, total income of the assessee is assessed u/s 143(3) of the Income Tax Act, 1961 as under: Total Income as per return Rs. 3,541/- Addition on account of undisclosed interest income (As discussed in para-6)Rs. 17,52,500/- Addition u/s 14A as discussed above (As discussed in para-7)Rs. 25,709/- Addition on account of share dealing profit (As discussed in para-6) Rs. 72,500/- Assessed income [u/s 143(3)] Rs. 18,54,250/-" 5. The assessee dissatisfied with the above order filed the appeal before the ld. CIT(A), NFACT which was partly allowed. 6. Aggrieved by the said order dated 06.12.2021, the assessee is in appeal....