2023 (8) TMI 811

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....e ground raised by the assessee, in its appeal, is reproduced as under:- "i. In the facts and in the circumstances of the case the Assessing Officer erred in not giving deduction of interest paid of Rs. 4,05,206/- against the interest received and the learned Commissioner erred in confirming the stand taken by A.O. and dismissing the appeal without giving relief for deduction for interest paid of Rs. 4,05,206/- on borrowing of loan from parties." 3. In the larger interest of justice, the slight delay of 4 days in filing the present appeal is condoned. During the hearing, the learned Departmental Representative ("learned DR") also did not raise any objection against the condonation of the aforesaid delay. 4. The only dispute raised by th....

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...., the AO disallowed the interest expenditure of Rs. 4,05,206 claimed by the assessee. The learned CIT(A), vide impugned order, dismissed the appeal filed by the assessee. Being aggrieved, the assessee is in appeal before us. 6. During the hearing, the learned Authorised Representative ("learned AR") submitted that the assessee has borrowed from several parties on which interest was paid and the assessee has earned interest income on a loan given to its group concern, namely Maple Infra Projects Limited. The learned AR referred to the chart on pages 3-5 of the paper book and submitted that before giving loans to its group concern on which it earned interest income, the assessee received the interest-bearing funds from several parties. 7. O....