2025 (8) TMI 1420

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....Act on 16-03-2024. The grievance of the assessee is two-fold i.e., (i) Confirmation of addition of Rs. 58.83 Crores u/s 69A; (ii) Addition of interest income for Rs. 1.98 Crores. 2. The Ld. AR advanced arguments with the support of documents on record and made various submissions. The Ld. CIT-DR also advanced arguments supporting the orders of lower authorities. Having heard rival submissions and upon perusal of case records, our adjudication would be as under. Assessment Proceedings 3.1 The assessee being resident individual is stated to be engaged in money-lending business. The assessee admitted interest income of Rs. 40.73 Lacs as Business income. The assessee opted for presumptive taxation scheme u/s 44AD. Upon perusal of return of ....

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....d have funds or capital to the tune of Rs. 6.01 Crores. Further, loans in money lending business were short term for 3-4 months which would mean that the capital would be rotated for 3-4 times during the year. Assuming rotation of 4 times, the assessee would have funds to the extent of Rs. 24.05 Crores as against debtors of Rs. 82.88 Crores as reflected by the assessee. The differential of the two i.e. Rs. 58.83 Crores was added as unexplained money u/s 69A of the Act. 3.5 The Ld. AO also proceeded to estimate the income of the assessee considering debtors of Rs. 82.88 Crores assuming interest rate of 18%. The same would translate into interest income of Rs. 14.92 Crores. The assessee reflected gross receipts of Rs. 1.69 Crores which would....

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....estroyed and therefore, the same was not available for submissions. However, as required by Ld. CIT(A), the assessee could not furnish full particulars of income, monthly opening and closing amount of loans provided to debtors as well as other details as called for by Ld. CIT(A). The assessee also assailed the invocation of Sec. 69A. 4.2 After due consideration, Ld. CIT(A) held that the required details including basis of gross receipts of Rs. 169.71 Lacs was not furnished. Further, in the earlier return of income, opening debtors were reflected as 'nil'. Under these circumstances, the findings of Ld. AO were endorsed and both the additions were confirmed against which the assessee is in further appeal before us. Our findings and Adjudica....