TaxTMI 
TaxTMI 
2025 (7) TMI 1115
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....essment passed u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') dated 28.12.2019 by the Assessing Officer, ACIT, Circle-28(1), Delhi (hereinafter referred to as 'ld. AO'). 2. The first issue to be decided in this appeal of the revenue is as to whether the ld CIT(A) was justified in deleting the disallowance made in the sum of Rs. 1,83,57,397/- on account of payment made u/s 37(1) of the Act. 3. We have heard the rival submissions and perused the material available on record. The return of income for the AY 2017-18 was filed by the assessee on 31.10.2017 declaring total income of Rs. 10,54,01,650/-. The assessee was engaged in the business of mining, contractual work and other related work under the name and st....
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....C- Rs. 42,10,798/- d. Rajkumar Patel (transporter)-BGDPP 9980J- Rs. 16,98,336/- e. Raj Kumar Soni (transporter)-AOQPS 2722H- Rs. 26,43,495/- f. Shiv Kumar Patel (transporter)-CFAPP 5343A- Rs. 10,48,329/- g. T. R. Soni (transporter)-AOQPS 2721E- Rs. 38,72,308/- h. Umesh Kumar Trivedi (transporter) ARPPT 9253Q- Rs. 13,66,189 Rs. 183,57,397/- 4. For all these parties, the ld AO had observed that the assessee had submitted the copy of confirmations, copy of invoices and copy of bank statement. It was observed that the copy of bills submitted by the assessee was matching with the confirmation account and imprest amount paid to the account of Shri D. Banerjee for onward payments. However, the amount of imprest pa....
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....ed that the payments were made through regular banking channels. Hence we hold that the disallowances made by the ld AO u/s 37 of the Act with regard to payment made to the transporters have been rightly deleted by the ld CIT(A). Accordingly, Ground Nos. 1 and 2 raised by the revenue are hereby dismissed. 5. Ground Nos. 3 and 4 raised by the revenue are challenging the deletion of interest of Rs. 53,86,044/-. 6. We have heard the rival submissions and perused the material available on record. The assessee had debited total interest in its profit and loss account in the sum of Rs. 7,15,18,095/-. The assessee had indeed advanced interest free loans and advanced to certain parties to the tune of Rs. 4,48,83,699/-. It was contended that these....