2025 (3) TMI 2005

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....l grounds which do not call for recording of any specific finding. 2. In Ground No.2 assessee has pleaded that ld. CIT(A) has erred in upholding the disallowance of interest expenditure amounting to Rs. 2,22,780/-. 3. The brief facts of the case are that assessee company at the relevant time was engaged in construction of roads and other development activities. It has filed its return of income electronically on 20.11.2014 declaring total income of Rs. 1,24,51,890/-. The case of the assessee was selected for scrutiny assessment and a notice under Section 143(2) was issued and served upon the assessee. On scrutiny of the accounts, it revealed that assessee has advanced a sum of Rs. 7,82,243/- to three individuals, namely; Nitin Bansal ....

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....ond ground is allowed and the disallowance out of interest expenditure amounting to Rs. 2,22,780/- is deleted. 6. In Ground No.3 assessee has pleaded that ld. CIT(A) has erred in upholding the addition of Rs. 47,64,800/- which was added by the AO with the aid of Section 68 of the Income Tax Act. We find that assessee has taken a loan of Rs. 47,64,800/- from four individuals namely, Deepak Rawa Rs. 25 lacs, Harish Rs. 5 lacs, Sarika Rana Rs. 5 lacs, Kanta Rani Garg Rs. 12,64,000/-. According to the AO, assessee failed to submit requisite details for fulfilling the conditions enumerated under Section 68, hence AO made the addition. 7. Before ld. CIT(A), assessee has submitted copy of PAN number of each creditor, copy of the Bank Stateme....

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....ndicate that assessee has fulfilled all the ingredients. It has submitted the copy of Permanent Account Number of each individual that would prove his identity as well as status of the creditor that he/she is an income tax assessee. In order to prove credit worthiness, assessee has filed copy of the ITR. Assessee has filed banking details exhibiting the amount received by it. The AO called for information under Section 133(6) of the Income Tax Act. All the creditors have responded to the letter of AO and submitted the requisite details. They have confirmed that they have given loan to the assessee. Thus, we fail to appreciate as to how assessee failed to prove identity, credit worthiness and genuineness of the transaction as observed by the....