2025 (2) TMI 1649

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....TBA/NFAC/S/250/2024-25/1068814844(1) dated 19.09.2024 for the A.Y.2018-19 arising out of the order passed under section 143(3) of the Income Tax Act, 1961 (in short 'Act') dated 05.06.2021. 2. Brief facts of the case are that, assessee filed his return of income on 04.12.2018 admitting a total income of Rs. 31,07,860/-. The case was selected for limited scrutiny assessment under the E-assessment Scheme, 2019 on the following issues: - i. Verification of genuineness of Expenses ii. Unsecured loans 3. Thereafter, notices under section 143(2) and 142(1) of the Act were issued on 18.12.2019 and 11.02.2020 calling for details. Subsequently, show- cause notice was also issued on 29.04.2021. After examining the assessee sub....

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.... case and in law so far as the first appellate order passed by him is prejudicial to the interest of the Appellant and confirming the demand, ignoring the evidences are bad in law and arbitrary. 2. That the Learned CIT (A) erred in confirming the demand of Rs. 60,55,302/- in toto made by the learned AO though the appellant had adduced the evidences in proof of the payments and cash credits. a) Confirmed the addition u/s. 68 Rs. 52,99,941/- b) Disallowance of interest u/s.37(1) Rs. 49,000/- c) Disallowance of expenses u/s. 37(1)  Rs. 22,226/- 3. Each one of the above grounds of appeal is without prejudice to each other. 4. That the appellant craves leave to add/alter any of the groun....

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....N Amount of loan or deposit taken or accepted during the year Interest paid 1. Akshay Engineering EKOPS6093D 1,500,000   2. Electromech Engineers AABFE5162G 2,200,000   3. Jumana Qaid Zohar Shahp urwala AVVPK0881D 700,000   4. Mariya Siraj Bhai AONPS3117D 500,000   5. Priyanka Sharma ASCPD6399R 799,941 39200 6. Sarada Devi Palod AIKPP1773F 200,000 9800 7. Farida Patel   200,000   8. TN Enterprises   700,000   10. However, we find from the observations of the Ld. AO that in response to notice under section 133(6) of the Act only partial information has been submitted by the v....