2025 (11) TMI 283

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....vastava, Sr. D.R. ORDER PER SUCHITRA KAMBLE, JUDICIAL MEMBER: This is an appeal filed against the order dated 31-12- 2024 passed by National Faceless Appeal Centre (NFAC), Delhi for assessment year 2017-18. 2. The grounds of appeal are as under:- "a. The Ld. CIT(A) erred in confirming the order of the AO making Disallowance u/s 36(1)(iii) to the extent of Rs. 10,39,500/-. ....

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....17, yielding short term capital of Rs. 81,391/- in assessment year 2017-18 and Rs. 8,19,200/- for assessment year 2018-19 which was offered to tax in relevant assessment year. The case was selected for scrutiny and assessment was completed u/s. 143(3) on 10-12-2019 wherein the Assessing Officer disallowed Rs. 10,39,500/- u/s. 36(1)(iii) alleging thereby the diversion of borrowed fund for investmen....

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.....R. submitted that in the relevant assessment year 2017-18, the assessee has yielded short term capital gain of Rs. 81,391/- and in subsequent yeas it was Rs. 8,19,200/- and in both the assessment years the said amount was offered to tax. In respect of balance 4 crore, the same was reflected in the subsequent years and this crucial fact was not taken into account by the Assessing Officer. At page ....