TaxTMI 
TaxTMI 
2024 (2) TMI 880
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....al in nature and needs no separate adjudication. 4. Ground No. 2 relates to the deletion of addition of Rs. 1,24,12,036/- on account of disallowance of claim of deduction u/s 35AC of the Income-tax Act, 1961 [the Act, for short]. 5. While scrutinizing the return of income, the Assessing Officer noticed that the assessee has claimed deduction u/s 35AC of the Act amounting to Rs. 1,24,12,036/-. The Assessing Officer observed that the assessee has not brought on record details/necessary evidences for being eligible to claim such deduction. Therefore, the assessee was show caused to justify its claim of deduction. 6. The assessee filed detailed reply explaining the claim. But the reply of the assessee was simply dismissed by the Assess....
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....nterest Charge Sahara India Commercial Corp. Ltd. Rs. 13,84,89,156/- NIL NIL Sahara India Rs. 17,86,78,438/- Rs. 9,15,34,8121- NIL The Assessing Officer observed that the assessee has not shown interest income on the aforementioned loans and advances. 14. A show cause notice was issued to the assessee asking it to explain as to why interest @ 12% may not be imputed on the average of opening and closing loans outstanding against the aforementioned related parties. 15. The assessee filed detailed reply which did not find any favour with the Assessing Officer who proceeded by imputing interest @ 12% and made addition of Rs. 1,43,63,802/-. 16. When the matter was agitated before the ld. CIT(A), it was explain....
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.... scrutinizing the return of income, the Assessing Officer noticed that there was huge investment under the head "Non-current investment". Invoking the provisions of section 14A of the Act r.w.r. 8D of the ITAT Rules, the Assessing Officer computed disallowance at Rs. 6,13,17,433/-. 22. Before the ld. CIT(A), it was explained that the assessee was carrying on business of residuary non-banking company registered with RBI and in pursuance of RBI guidelines, 'Directed Investments" are required to be made which are "business investments'. Whatever income is accruing from these investments, the same is being offered under the head "Profits and gains of business or profession", meaning thereby, that there is no exempt income claimed by the asse....
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....s. 14,63,91,339/-. It was explained before the Assessing Officer that Sahara India Commercial Corporation Ltd. has shown an amount of Rs. 2.73 crores as prior period expenses and rest Rs. 14.63 crores pertains to the relevant F.Y which has been shown by the assessee as income. 30. This plea was rejected by the Assessing Officer who proceeded to make the impugned addition. 31. Before the ld. CIT(A), the assessee reiterated its claim. 32. After verifying the facts from the ledger account and after being satisfied with the entries/narrations, the ld. CIT(A) deleted the impugned addition. 33. Before us, the ld. DR could not bring any factual error in the findings of the ld. CIT(A). 34. After verifying the facts, we are of the con....