2025 (1) TMI 752

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....R PER VIKAS AWASTHY, JM: This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [in short 'the CIT(A)'] dated 24.01.2024, for Assessment Year 2021-22. 2. The assessee in appeal has raised multiple grounds, all the ground are in respect of single issue i.e. disallowance of interest expenditure in respect of assess....

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..... The Assessing Officer rejected contention of the assessee and taxed the entire interest income and disallowed interest expenditure in full. Aggrieved by the assessment order dated 19.10.2022, the assessee filed appeal before the CIT(A). The First Appellate Authority without appreciating the facts and submissions of the assessee upheld disallowance of interest. Hence, the present appeal. 3.1. Th....

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....minor son of assessee is not emanating from submissions of the assessee and the documents on record. The CIT(A) has given a categoric finding that earning of interest by minor child is unrelated to the loans taken by the appellant and interest paid thereon. He further asserted that no material was placed on record by the assessee to substantiate that the loans taken on which interest was paid is i....