TaxTMI 
TaxTMI 
2025 (2) TMI 1528
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....nal Faceless Appeal Centre (NFAC) erred in upholding the decision of Ld.AO of disallowing Rs. 11,41,095/- on account of interest claimed in profit & loss A/c u/s. 36(1)(iii) of the act without considering the submission preferred and judicial precedents identical to its case quoted by the appellant. The appellant company prays that the said disallowance may please be deleted. 2. This ground raised by the assessee relates to challenging the order of disallowance of interest u/s. 36(1)(iii) of the Act. In this regard, Ld. AR appearing on behalf of the assessee outrightly submitted that this ground is squarely covered in favour of assessee by the decision of the Coordinate Bench of ITAT in assessee's own case in ITA No. 2726/Mum/2023 for th....
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....roportionate interest expenditure of INR 21,48,282 in respect of the interest-free advances given to the related parties. The learned CIT(A), vide impugned order, dismissed the appeal filed by the assessee on this issue. 6. We have considered the submissions of both sides and perused the material available on record. From the perusal of the Balance Sheet of the assessee for the year ending 31/03/2013, forming part of the paper book from pages 1-18, we find that the assessee has share capital and reserves and surplus of INR 4,35,09,958, which is more than interest-free loan of INR 1,41,49,131, advanced by the assessee to the related parties. We find that the Hon'ble Jurisdictional High Court in CIT v/s Reliance Utilities & Power....
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....nds allowed. Ground No. 2 On the facts and in the circumstances of the case and in law, the Hon'ble National Faceless Appeal Centre (NFAC) erred in upholding the decision of the Ld.AO of disallowance of Rs. 18,66,766/- on account of expenses claimed in profit & loss A/c under the head Sales Promotion Expenses without considering the submission preferred and judicial precedents identical to its case quoted by the appellant. The appellant company prays that the said disallowance may please be deleted. 7. This ground raised by the assessee relates to challenging the disallowance of sales promotion expenses claimed in profit and loss account. In this regard, the Ld. AR appearing on behalf of the assessee submitted that ....
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....allowance u/s. 14A r.w.s 8D of the Act. In this regard Ld. AR submitted that this ground is also squarely covered in favour of assessee by the decision of the Coordinate Bench of ITAT in assessee's own case in ITA No. 2726/Mum/2023 for the A.Y 2009- 10. 11. Whereas on the contrary, the Ld. DR relied upon the orders passed by the revenue authorities. 12. I have heard the counsels of both the parties and I have also perused the material placed on record, judgments cited by the respective parties and the orders passed by the revenue authorities. I noticed that the identical ground has already been decided by the Coordinate Bench of this Tribunal in assessee's own case for A.Y 2009-10 and I am of the view that The Assessee's share cap....