2024 (7) TMI 1232

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....lates to AY. 2018-19. Though the assessee has raised seven grounds of appeal, the assessee did not press Grounds No. 2 to 4. The remaining grounds are relating to the following issues: a. Addition of interest income of Rs. 12.02 crores; b. Disallowance made under Section 14A of the Act at Rs. 13.45 crores; 2. The first issue relates to addition of interest income of Rs. 4.02 crores. The assessee had declared interest income of Rs. 20,76,070/- in its return of income. From an internal portal named 'insight portal', which could be viwed by the Assessing Officer only, the AO noticed that the assessee has received interest income from the following persons: S.No. Name TAN Amount of Interest Rs. 1. Essar Oi....

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....ee could not have offered explanations with regard to the information available in the 'insight portal', unless the relevant information were supplied to the assessee. We find merit in the above said submissions of Ld A.R. The Principles of natural justice would require the AO to confront the materials relied upon by him for making the addition. In the instant case, we are of the view that there is violation of the above said principle. Accordingly, we are of the view that this issue needs a fresh examination at the end of the Assessing Officer. Accordingly, we set aside the order passed by the Ld.CIT(A) on this issue and restore the same to the file of the Assessing Officer for examining it afresh, after providing the relevant material to ....