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TMI Blog2021 (4) TMI 345X X X X Extracts X X X X X X X X Extracts X X X X ..... gainst order dated 31/08/2016 passed by CIT(A)-Meerut for assessment year 2012-13. 2. The grounds of appeal are as under : - "1. (a) That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in sustaining the disallowance of interest of Rs. 99,14,425/- under proviso to Section 36(1)(iii) of the Income Tax Act, 1961. Observations made, inferences drawn and findings recorde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee in its profit and loss account as the same are not allowable as per proviso to Section 36(1)(iii) of the Act and disallowed the same. 4. Being aggrieved by the assessment order, the assessee filed appeal before the CIT(A). The CIT(A) partly allowed the appeal of the assessee. 5. The Ld. AR submitted that the assessee has given details of interest expenses as debited in the profit and l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e purchased machinery for Rs. 3,48,04,787/-. The same was purchased from the loan availed and the internal accrual of the company. A certificate from the bank regarding completion of project was given by the assessee along with details of machinery purchased, thereby depicting the fact that 76% of the project was completed by September, 2011. The machinery was purchased and put to use during the p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ied by the Assessing Officer as well as by the CIT(A). Therefore, it will be appropriate to remand back the issue to the file of the Assessing Officer for proper adjudication in respect of the evidences produced by the assessee and thereafter pass an appropriate order in accordance with law. Needless to say, the assessee be given opportunity of hearing by following principles of natural justice. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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