2026 (4) TMI 642

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... ORDER PER BENCH: This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the "Ld. CIT(A)"] dated 26.06.2025 for the AY 2017-18. 2. The only issue raised by the assessee is against the order of ld. CIT(A) confirming the order of ld. AO wherein the interest expenditure paid to the members of the appellant GPF....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e Bench in the year 2016-17, however, relied heavily on the order of ld. lower authorities. 5. After hearing the rival contentions and perusing the materials available on record, we find that the issue is squarely covered by the decision of the co-ordinate bench in own case in which the interest expenditure paid to the members of the GPF Trust was allowed by observing and holding as under:- ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....the Act to the extent of the exempt income but enhanced the interest disallowance to Rs. 6,42,82,320/-. The basis of disallowance by the Revenue authority is that there is no nexus between the interest expenditure and the income earned thereon. We, however, fail to find any merit in such finding of the Revenue authorities because the assessee is a G.P.F. Trust and is an association of persons. Sou....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....his ground raised by the assessee is also allowed for statistical purposes. 10.3. Ground no. 3 is general in nature which needs no adjudication. 10.4. In the result, the appeal filed by the assessee in ITA No. 364/GTY/2019 is allowed for statistical purposes. 11. In the result, the appeals filed by the assessee in ITA Nos. 360 & 361/GTY/2019 are partly allowed, ITA No. 3....