2026 (4) TMI 974

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....r, CA For the Revenue : Dr. Priyanka Patel, Sr. DR ORDER PER PARTHA SARATHI CHAUDHURY, JM: The present appeal preferred by the assessee emanates from the order of the Ld.CIT(Appeals)/NFAC, Delhi dated 04.09.2025 for the assessment year 2022-23 as per the grounds of appeal on record. 2. The brief facts in this case are that the assessee is an individual engaged in the business of tra....

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..... A/c- Rs. 18,84,000/-(20% of 94,20,000/-). 3. Thereafter, the assessee had duly submitted the supporting documents evidencing the genuineness of Unsecured loans and the same was duly accepted by the A.O and the proposed variation of Rs. 2,60,50,000/- with regard to unsecured loan was dropped. That further, in response to the proposed variation of 20% disallowance of various cash expenditure, t....

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.... went before the First Appellate Authority, the Ld. CIT(Appeals)/NFAC restricted the disallowance amounting to Rs. 94,200/- while deleting the remaining amount of Rs. 3,76,800/- out of total disallowance of Rs. 4,71,000/-. 5. We have heard the rival contentions of the parties herein, carefully considered the documents on records and analyzed the facts and circumstances in this case. Admittedly,....

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....ve that the A.O had neither doubted the genuineness of the books of account nor resorted to Section 145(3) of the Act. That power of the Ld. CIT(Appeals)/NFAC is coterminus with that of the A.O who had also not conducted any independent inquiry as mandated u/s. 250(4)&(6) of the Act and simply had confirmed ad-hoc disallowance of Rs. 94,200/- and at the same time accepting the genuineness of the t....