2026 (5) TMI 1469

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....oned appeal at the instance of assessee pertaining to A.Y. 2020-21 is directed against the order dated 05.12.2025 framed by National Faceless Appeal Centre, Delhi arising out of Assessment Order dated 20.09.2022 passed u/s. 143(3) r.w.s.144B of the Income Tax Act, 1961 (in short 'the Act'). 2. The sole grievance of the assessee is disallowance of interest at Rs. 21,97,114/- claimed by the asses....

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.... and Bafna Realtors Pvt. Ltd. from which major amount of interest was received @6%. Assessee stated that the above referred companies are related parties as the assessee is Director in both these companies and therefore less rate of interest has been charged. However, ld. Assessing Officer was not satisfied and he took the benchmark of 6% interest rate and recomputed interest payment by applying 6....

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....dvances are Rs. 17.21 crore. I find that the two parties namely Pancharatna Buildcon Pvt. Ltd. and Bafna Realtors Pvt. Ltd. are related to the assessee as he is a Director in both these companies and the loans have been given for commercial expediency purposes and therefore even if low rate of interest has been charged the same should be accepted. I also take note of the funds available with the a....