2023 (1) TMI 1227

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....e Return of Income for the assessment year 2013-14 was filed on 28.09.2013 declaring total income of Rs.3,66,66,193/-. Against the said return of income, the assessment was completed by the Assistant Commissioner of Income Tax, Satara Circle, Satara ('the Assessing Officer') vide order dated 30.11.2015 passed u/s 143(3) of the Income Tax Act, 1961 ('the Act') at a total income of Rs.4,27,67,764/- after making the following additions :- (i) The amount directly credited to Reserve Fund - 3,11,237/- (ii) Disallowance of provision of Standard assets - 10,00,000/- (iii) Disallowance of broken period interest - 33,22,899/- (iv) Disallowance of amortization of premises - 4,88,614/- (v) Disallowance of special Reserve u/s 36(1)(viii) ....

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....rued the appellant. 6. The ld. AR submits that the appellant is specified entity within the meaning of sub-clause 4A of Explanation inserted to the provisions of section 36(1)(viii) and also carried on the eligible business and complied with all the conditions prescribed under the provisions of section 36(1)(viii) of the Act. The ld. AR submits that the lower authorities have misconstrued the term "development of housing in India". 7. On the other hand, ld. Sr. DR placed reliance on the orders of the lower authorities. 8. We heard the rival submissions and perused the material on record. The ground of appeal no.1 challenges the decision of the ld. CIT(A) confirming the addition of Rs.3,11,237/- being the amount transferred to the capital....