2023 (6) TMI 436

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.... the order dated 25-01-2023 passed by the CIT(A) in National Faceless Appeal Centre, Delhi u/s.250 of the Income-tax Act, 1961 (hereinafter also called 'the Act') in relation to the assessment year 2014-15. 2. The first issue raised in this appeal is against the confirmation of addition of Rs. 5,30,186/- in respect of opening balances of the trade creditors, namely, M/s. P.M. Engineers and Cont....

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....de, the opening and closing balance for the preceding year, namely, as on 01-04-2013 and 31.3.2014, as appearing in the books of account of the assessee stood at Rs. 1,30,504/-. The AO observed that the addition made in the preceding year due to non-reconciliation in this account was Rs. 4,42,663/-. He made further addition of Rs. 1,30,473/- towards difference in the opening balance as was not add....

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....r, then he ought to have made addition for the full difference in the preceding year. Having not made full addition due to non-reconciliation of the balances in the preceding year, and there being no fresh transactions, the AO cannot be allowed to make addition in the current year towards opening balances. I, therefore, order to delete the addition. 5. The only other ground is against the confi....

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....e 6 that the total of investments yielding exempt income stands at Rs. 67,95,634/. As against that, the assessee's capital is Rs. 1.64 crore. The Hon'ble Bombay High Court in CIT vs. Reliance Utilities and Power Ltd. (2009) 313 ITR 340 (Bom), has held that where an assessee possessed sufficient interest free funds of its own which were generated in the course of relevant financial year, apart ....