2025 (2) TMI 1378

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....ilen Samadder, Addl. CIT- Sr. DR ORDER PER SONJOY SARMA, JUDICIAL MEMBER: The present appeal has been preferred by the assessee against an order dated 11.12.2024 of the National Faceless Appeal Centre [hereinafter referred to as 'CIT(A)'] passed u/s 250 of the Income Tax Act (hereinafter referred to as the 'Act'). 2. Brief facts of the case are that the assessee filed its return of inc....

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....liance, the investment could not be identified and income from the said investment could not be verified. Accordingly, the Assessing Officer on hypothetical basis made 1% of the investment of Rs. 29,65,14,500/- amounting to Rs. 29,65,145/- is treated as income out of the investment made. It was also observed that the assessee has interest income from loans & advances of Rs. 3,03,06,302/-. Due to n....

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....is without any concrete findings, which is illegal. Similarly, an addition of 12% of the notional interest of Rs. 36,36,756/- on interest income on loans & advances was arbitrary and lack of any substantive basis. The ld. AR submitted that all the relevant books of accounts were produced before the Assessing Officer. However, the Assessing Officer made the addition without rejecting the books of a....

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....thority below are just and proper therefore, appeal may be dismissed. 6. We, after hearing both the parties and perusing the materials available on record, find that both the additions were made purely on notional or hypothetical basis without any concrete evidences and proper verification. Since while framing of the assessment order, the Assessing Officer did not reject the books of accounts o....