2023 (9) TMI 541

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....RDER PER SHRI RAJPAL YADAV, VICE-PRESIDENT (KZ):- The present appeal is directed at the instance of assessee against the order of ld. Principal Commissioner of Income Tax-3, Kolkata dated 20th February, 2020 passed under section 263 of the Income Tax Act, 1961 in A.Y. 2015-16. 2. In response to the notice of hearing, Shri Ashish Gupta, ld. C.A. has filed an application for adjournment contendin....

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.... & Country Planning within the due date stipulated in the agreement but rather payment was delayed. On such delayed payment, an interest of Rs. 47,50,000/- has been claimed as expenditure. In the opinion of ld. Pr. CIT, this expenditure ought to have been disallowed to the assessee by the ld. Assessing Officer on the ground that it is penal in nature. 4. On due consideration of the facts and circ....