2022 (12) TMI 249

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....f appeal: "1. On the facts and circumstances of the case as well as in law, the Learned CIT(A) has erred in confirming the action of Learned Assessing Officer in making an addition in the assessment order passed u/s. 143(3) r.w.s.153A of the Income Tax Act, 1961 without any incriminating documents found during the course of search action. 2. On the facts and circumstances of the case as well as in law, the Learned CIT(A) has erred in confirming the action of Learned Assessing Officer in making an addition of Rs.4,290/- on account of alleged penal interest levied on short deduction/ no deduction of TDS, without considering and appreciating the facts and circumstances of the case as it was not emanate from search action. 3. On the fac....

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....ve expenses and debited the same to balance sheet for capitalisation to WIP. No interest has been charged to P&L Account of the assessee. AO further noticed that total unsecured loan as on 31-03-2010 were Rs 1,18,45,000/- out of this assessee further given loan to sister concern amounting to Rs 84,47,690/-. AO worked out the proportional amount of interest to be disallowed u/s 36(1)(iii) amounting to Rs 12,24,830/-. 4. Aggrieved with this order of AO assessee filed an appeal before the Ld. CIT(A)-54 Mumbai. Ld. CIT(A) deleted the addition of Rs 1,00,27,875/- on the ground that the same has already been added in the hands of M/s Samira Habitat India Ltd (sister concern) but the addition ofRs 12,24,830/- Ld. CIT(A) also sustained and upheld ....