2026 (4) TMI 974

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....iyanka 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 trading of tendu leaves (forest prod....

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....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, the assessee has duly mentioned th....

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....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, the assessee herein deals with t....

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....ed 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 transactions reflected in the book....