2024 (5) TMI 1499

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....: Shri S. Datta, CITDR ORDER PER RAJESH KUMAR, AM: This is the appeal preferred by the assessee against the order of the Ld. Commissioner of Income Tax (Appeals)-NFAC, Delhi (hereinafter referred to as the Ld. CIT(A)"] dated 08.11.2023 for the AY 2013-14. 2. In ground no. 1 to 6, the assessee has challenged the reopening of assessment u/s 147 read with Section 148 of the Act which was ....

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....nt to AY 2012-13 of Rs. 30,00,000/- on 16.09.2011 and also debited interest of Rs. 1,17,230/- on that accommodation entry. Consequently after recording reason to believe u/s 148(2) of the Act, the case was reopened u/s 147 by issuing notice u/s 148 of the Act on 4.3.2012. The assessee filed various details/information as directed by AO during the course of assessment proceedings in respect of unse....

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....n recorded a finding that the issue of loans of Rs. 4,80,00,000/- was already examined by the AO during the assessment proceedings which culminated u/s 143(3) of the Act and therefore the addition of Rs. 4,80,00,000/- and interest of Rs. 80,50,500/- were deleted by the Ld. CIT(A) by holding that the corresponding unsecured loans were already accepted in the preceding and succeeding assessment year....