2025 (3) TMI 2068

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.... Meena, Sr. DR ORDER PER SATBEER SINGH GODARA, JUDICIAL MEMBER: This assessee's appeal for Assessment Year 2018-19, arises against the CIT(A)-30, New Delhi's DIN & order No. ITBA/APL/M/250/2023-24/1058827580(1) dated 18.12.2023, in proceedings u/s 143(3) of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties at length. Case file perused. 3. The assessee pleads t....

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.... sustained addition of Rs. 19,98,738/-. 3. Without prejudice to both the above grounds of appeal, the Learned C.I.T. (A) has erred both on facts and in law in considering this amount of Rs. 19,98,738/- as bogus interest payment (effectively) without considering the general submissions made by the appellant in this behalf." 4. Both the learned representatives reiterate their respective ....

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....ile that the learned lower authorities have nowhere treated the assessee as having failed to explain source of the impugned interest expenditure as they have invoked section 69C of the Act for treating it as a bogus claim. This is more so, in light of the fact that the loan amount itself stood added in the course of assessment and deleted in the lower appellate proceedings. 7. Faced with this s....