2025 (4) TMI 1875

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....ER ANNAPURNA GUPTA, ACCOUNTANT MEMBER: The present appeal has been filed by the assessee against the order passed by the learned Commissioner of Income-tax (Appeals) [in short "CIT(A)"] u/s. 250(6) of the Income-tax Act, 1961 (hereinafter referred to as "the Act"). 2. Grounds raised by the assessee are as under : 1. On the facts and circumstances of the Case The learned C.I.T.(A) er....

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....s account under the head 'interest on vehicle loan'. In the assessment framed u/s. 143(3) of the Act, the said claim of the assessee was allowed, but thereafter re-assessment proceedings were initiated noting that no TDS had been made on the payment of interest. 4. During the assessment proceedings, the assessee pointed out that as per prevailing provisions of law in this regard, if the payee i....

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....ed in Form No. 26-A certified as tax paid there on by the payee by the Accountant amounting to Rs. 2,47,843/-. In the absence of any explanation of the difference, the Assessing Officer held that the veracity of Form 26-A furnished by the assessee was doubtful. He accordingly rejected the certificate furnished by the Accountant and went on to treat the entire amount of Rs. 2,47,843/- as disallowab....

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....justed only to the difference. We find merit in this contention of the assessee and we find the act of the learned CIT(A) disallowing the entire amount of interest paid to be grossly unjustified. It is nobodies' case that the certificate furnished by the Accountant in Form 26-A was false or incorrect. The only anomaly was in respect to the figure of the amount of interest certified by the Accou....