2025 (12) TMI 616

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....ER PER M. BALAGANESH, A. M.: 1. The appeal in ITA No. 385/AGR/2025 for AY 2017-18, arises out of the order of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as 'ld. NFAC', in short] dated 19.06.2025 against the order of assessment passed u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') dated 21.12.2019 by the Assessing Officer, Agra (h....

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....sessee had disclosed business loss of Rs. 3,89,911/- under the head income from other sources worked out as under:- a. Interest from Saving Bank A/c. Rs. 18,704/- b. Sale Mud Rs. 15,93,420/- c. interest received Rs. 1,01,85,872/-     Rs. 1,17,97,996/-   Interest paid Rs. 1,21,87,907/-   Loss (-) 8,89,911/- 4. The assessee....

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....s and in the year of advancing loans i.e. in the earlier years in the scrutiny assessment proceedings for AYs 2013-14 to 2015-16. In the earlier scrutiny assessment proceedings the ld AO had duly granted deduction on account of interest paid on loans under the head income from other sources. Even in subsequent AYs i.e. 2018-19 and 2020-21, the ld AO disallowed the interest paid on loans under the ....

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.... nor granted during the year, there is no question of proving any nexus between the same. Despite this assessee had given the complete details of opening balance of loans borrowed together with the details of interest paid thereon before the ld AO. Similarly, the assessee had given the details of opening balance of loans and advances and interest income earned thereon before the ld AO. Despite the....