2025 (4) TMI 1974

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....taining to Assessment Years 2017-18 & 2018-19. 2. The grounds raised are as under:- A.Y. 2017-18 "1. Whether, on the facts and in the circumstances of the case and in law the Ld.CIT(A) has erred in not appreciating that the assessee, during the assessment proceedings, was not able to provide any explanation in respect of wrong allocation of expenses in order to inflate the profit from the housing loan segment in order to avail the deduction u/s 36(1)(vii) of the Act and accordingly, in deleting the disallowance of Rs. 3,27,24,467/-." 2. "The appellant craves to be allowed to add any fresh ground(s) of appeal and or deleted or amend any of the ground(s) of appeal," A.Y. 2018-19: 1 (i) 1. "Whether in facts ....

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....e ld. DR fairly agreed with the same. 4. A perusal of the orders of the authorities below reveal that the assessee is engaged in the business of housing finance which includes housing loans as well as loans against property. The assessee had claimed deduction on account of special reserves created from its profits of the eligible business of housing finance in terms of the provisions of section 36(1)(viii) of the Act which provided for allowance of such reserves created for an amount not exceeding 20% of the profit derived from the eligible business computed under the head 'Profits and gains of business and profession.' The AO found that while computing the profits of the eligible business, the allocation of interest expenses incurred in....