TaxTMI 
TaxTMI 
2025 (5) TMI 2114
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.... for recording of any specific finding. 2. The Registry has pointed out that appeal is barred by 8 days. Revenue has fi led an application for condonation of delay. The Revenue has pleaded that there were lots of movements of fi le for taking necessary approval and due to this communication gap, it could not file the appeal within time. Taking into consideration the explanation of the DCIT, Circle-1, Chandigarh, we condone the delay in filing the appeal which is of a very short period and proceed to decide the appeal on merit. 3. We first take Ground 3. In this Ground, Revenue has pleaded that ld. CIT(A) has erred in deleting addition of Rs. 45,70,407/- which was added by the AO under Section 36(1)(iii) of the Act by making a disallowance....
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....the assessment order as well as the impugned order of the CIT(A) . We find that instead of pointing out user of interest bearing funds for the purpose of non business, the AO has only made reference with reference to the increase in inventory i.e. unsold cars/spares with the assessee. Similarly, he made reference to the increase of balance in the bank. We fail to understand that how these two components could goad any adjudicating authority to assume that interest bearing funds have not been used for the purpose of the business. The increase in the inventory in itself shows that higher funds were used for procuring those cars from manufacturers for sale. Thus, ld. AO miserably failed to demonstrate as to how interest expenditure is not allo....
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....s per receipts declared in the Profit & Loss A/c of the Return of Income filed. However, the AO has expressed reservation in giving credit for such TDS on the ground that party-wise details of such and ledgers of the same have not been provided. In his rejoinder the appellant states that such party-wise details have not been asked at any time during the assessment and also that the same would be evident in Form 26AS. Before me the party-wise and section-wise details reconciling a TDS made with the amount of receipts declared by him were also given as part of appellate proceedings and the same appear to be matched. 6.3.1 The AO is therefore directed to verify such reconciliation of TDS as per Form 26AS available with him and the party and....
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....business necessity, hence deleted the addition. 10. We have perused the finding of the ld. CIT(A) in paragraph No. 7.3 to 7.3.1 and we find that as far as Ford India Ltd. is concerned, it is the manufacturer of Ford cars, for whom assessee is working as Authorized Dealer. If few cars are supplied to the assessee on credit basis, then its credit balance will increase in the books of the assessee. Similarly, other one is a card being used for renewing the insurance of the car as well as for making insurance of new cars. How this increase in the credit could be construed as non-genuine by the AO is beyond our comprehension. Therefore, we are of the view that ld. CIT(A) has rightly deleted the addition. Ground No.2 11. In this Ground, Reven....