2025 (5) TMI 1560

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....AR For The Respondent : Shri S.K. Agal, Sr DR ORDER PER: DR. B.R.R. KUMAR, VICE PRESIDENT: This appeal has been filed by the assessee against the order passed by the Ld. Commissioner of Income-Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as "CIT(A)" for short) dated 18.06.2024, passed u/s 250 of the Income-tax Act, 1961, (hereinafter referred to....

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....appeal before the Ld. CIT(A) who dismissed the appeal of the assessee. 4. Aggrieved by the order of the Ld. CIT(A), the assessee is now in appeal before the Tribunal. 5. We have heard both the parties and perused the material available on record. Disallowance u/s 14A:- 6. The assessee has earned dividend of Rs. 2,83,383/- against which the Assessing Officer made disallowance of Rs. 3,1....

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....rores. Since the assessee has sufficient capital to advance loan of Rs. 11.62 lakhs, we hold that no notional interest is chargeable nor disallowable. Appeal of the assessee on Ground No. 6 is hereby allowed. Addition u/s 23(4) of the Act 8. The Assessing Officer determined notional rent @ Rs. 1 lakh per month, amounting to Rs. 12 lakhs per annum. The Ld. CIT(A) earlier determined the sam....