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TMI Blog2019 (1) TMI 31X X X X Extracts X X X X X X X X Extracts X X X X ..... rds the other issues raised by the ld. Pr. CIT in the show cause notice, those were not specifically discussed in the impugned order as the assessee explained some of the issues which were factually found to be correct. Accordingly, we restrict the fresh adjudication of the matter only on the issue of allowability of the claim under section 57(iii) of the Act, to that extent the impugned order of Pr. CIT is upheld. Following the order in the case of Shri Naresh Agarwal [2018 (8) TMI 1756 - ITAT JAIPUR] we uphold the impugned order of the CIT on the issue of allowability of the claim under section 57(iii) of the Act. - Decided against assessee. - ITA No. 701/JP/2018 - - - Dated:- 3-8-2018 - Shri Vijay Pal Rao, JM And Shri Vikram Singh Yadav, AM For the Assessee : Shri P.C. Parwal (C.A.) For the Revenue : Shri Varinder Mehta (CIT) ORDER PER VIJAY PAL RAO, J.M. This appeal by the assessee is directed against the revision order of ld. Principal CIT, Alwar dated 22.03.2018 passed under section 263 of the I.T. Act for the assessment year 2014-15. The assessee has raised the following grounds :- 1. The order passed by the ld. PCIT u/s 263 is illegal an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 12% Nangalwala Impex P. Ltd 28,46,839 (-) 59,03,647 (-) 30,56,808 33,96,453 15% The Madhur Glass Chem. Ind (Assessee is partner) 1,08,44,376 65,78,805 1,74,23,181 35,94,808 12% Vijay Agarwal - 9,00,000 9,00,000 1,500 15% BOB Delhi 486 BOB HC 12,361 HDFC Bank 944 IT Refund 12,610 Total 5,97,21,545 (-)1,47,98,039 4,49,23,506 75,40,217 Interes ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2,25,000 - 2,25,000 33,752 15% Pawan Agarwal 1,29,236 - 1,29,236 19,385 15% Rajkumar Agarwal 25,214 - 25,214 3,782 15% Saurbh Jain 1,00,000 7,930 16% Suresh Chand Agarwal 5,76,756 - 5,76,756 64,660 12% Total 5,20,88,471 (-)10,93,334 4,16,92,137 75,13,904 Thus identical transactions are involved in this case as in the case of Shri Naresh Agarwal. Both the parties have advanced identical arguments as raised in the case of Shri Naresh Agarwal. 4. Having considered the rival submissions as well as the relevant material on record, at the outset, we note that identical issues have been considered ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lance Interest received for the year Rate of inter est Nangalwal Impex Pvt. Ltd. (Assessee is a director) 1,04,89,313 (-) 80,33,000 24,56,313 2,78,164 15% Golden Vegpro Ltd. 21,86,007 1,33,721 23,19,728 3,43,222 15% Zibra Builders Pvt. Ltd. (Assessee is a director) 1,93,06,838 24,00,000 2,7,06,838 37,24,864 18% Ajanta Plastic Industries (Partner s capital 49,15,426 (-) 60,41,698 (-) 11,26,272 3,95,400 12% Vishal Agencies (Partner s Capital) 2,43,949 28,21,000 30,64,949 2,13,202 12% BOB 24,313 - 24,313 7,950 UBI 2,188 (-) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... - 2,00,000 24,000 12% Shushila Agarwal 6,50,000 (-) 1,50,000 5,00,000 76,438 15% Vishal Agencies (Partner OD) 1,07,02,272 - 1,07,02,272 19,26,409 18% LIC Loan 1,15,000 - 1,15,000 10,350 9% LIC Loan 3,22,000 - HDFC Loan 2,03,95,832 (-) 11,96,891 1,91,98,941 22,28,677 12.75% Total : 3,72,63,104 (-) 16,46,891 3,56,16,213 52,32,874 As it is evident from the above details that there are various transactions of loans given by the assessee as well as capital introduced in the old partnership firms by using the borrowed funds ..... X X X X Extracts X X X X X X X X Extracts X X X X
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