2025 (7) TMI 425

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....Gopal/Shri Akhilesh Deshmukh, A/Rs For the Revenue : Ms. Kavita P. Kaushik, Sr. D/R ORDER PER NARENDRA KUMAR BILLAIYA, AM: This appeal by the assessee is preferred against the order of the ld. CIT(A)/Addl./JCIT(A)-3, Bengaluru [hereinafter "the ld. CIT(A)"] dt. 14/10/2024 pertaining to AY 2017-18. 2. The sum and substance of the grievance of the assessee is that the ld. CIT(A) erred....

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....,293/- on account of payment of loan interest at Rs. 1,32,14,955/- and management fees of Rs. 73,338/- which resulted in a loss of Rs. 28,05,940/-. The AO asked the assessee to justify its claim of interest expenditure. The assessee filed a detailed reply which did not find any favour with the AO. The AO was of the opinion that the assessee has lent money to family concerns at lower rate of intere....

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....dvances Name Opening Balance as on- 1.04.2016 Addition during the years Repayment during the year Interest Rate Interest Amount TDS Sunil Capital & Securities Private Limited 2,31,38,261.25 2,59,00,000 2,50,00,000 8.50% 27,54,794 2,75,479 Vora Financial Services Private Limited 47,12,664 38,81,055 8,38,011 8.50% 4,80,625 48,063 JMP ....

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....or the assessee kept on harping on the argument that reasonableness cannot be questioned. 8. We are of the considered view that neither the AO nor the Bench was questioning the reasonableness of the expenditure. The only explanation sought was in respect of disparity of rate of interest charged from related parties and the unrelated parties because in our considered opinion, in similar transact....