2025 (2) TMI 1582

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....hobhit Mishra, A/Rs For the Revenue : Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R ORDER PER NARENDRA KUMAR BILLAIYA, AM: This appeal by the revenue is preferred against the order dated 09/02/2024 by the NFAC, Delhi [hereinafter 'the ld. CIT(A)'], pertaining to AY 2014-15. 1.1. Delay of 15 days is condoned. 2. The grievance of the revenue reads as under:- "1. Ground No.1 W....

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....ge?" 3. Ground No.3" Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) is justified in deleting the addition of Rs. 8,51,165/- towards consultancy fees, without considering the remand report of the AO wherein it is stated that the assessee has merely proved the identity of the receipient but failed to explain the nature of expenses, basis of payment, bus....

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....assessee was further asked to explain the interest payable of Rs. 41,41,016/- and consultancy fees of Rs. 8,51,165/-. On receiving no plausible reply, the AO made the impugned disallowance/additions. 5. Before the ld. CIT(A), the assessee filed additional evidence and requested for admission under Rule 46A. The ld. CIT(A) was convinced with the additional evidence and admitted the same and call....

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....the considered view that the assessee has successfully discharged the onus cast upon it by the provisions of Section 68 of the Act. Therefore, we do not find any reason to interfere with the findings of the ld. CIT(A). The impugned ground is dismissed. 7. The next grievance relates to the deletion of addition on account of consultancy fees amounting to Rs. 8,51,165/- paid to Tushar Vira. 8. ....