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TMI Blog2023 (2) TMI 448X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by the assessee before us that the assessee is entitled to get deduction on the interest received from Co-operative Bank is eligible for deduction u/s. 80P(2)(d) of the Act. Therefore, having no evidence before us, we find no infirmity in the order of CIT(A) and it is justified. Thus, ground No. 1 raised by the assessee is dismissed. Disallowance made on account of compound wall expenses - HELD THAT:- We note that the assessee did not submit any reply to the satisfaction of both the authorities below that a new compound wall erected at any place of the assessee s business premises. CIT(A) confirmed the order of AO in the absence of any evidence. Therefore, having no evidence before us, we find no infirmity in the order of CIT(A) and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the orders of this Tribunal and opposed the adjournment letter. On perusal of the grounds raised in Form No. 36, we find force in the submissions of ld. DR that the issues raised in the present appeal are covered by the orders of this Tribunal. Therefore, the adjournment letter filed by the assessee is rejected and we proceed to hear the appeal with the assistance of ld. DR and pass order on the examination of material available on record. 3. Ground No. 1 raised by the assessee challenging the action of CIT(A), NFAC, Delhi in restricting the deduction u/s. 80P(2)(d) of the Act. 4. We note that the assessee claimed benefit of deduction u/s. 80P(2)(a)(iii) of the Act. The AO was of the opinion that the activities carried on by the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2 raised by the assessee challenging the action of CIT(A), NFAC, Delhi in confirming the disallowance made on account of compound wall expenses. 6. We note that the AO issued show cause notice dated 19-12-2019 seeking explanation in respect of expenses relating to compound wall. The assessee did not file any reply till the date of finalization of order which is evident from para 5.3 of the assessment order. Therefore, the AO added the said amount to the total income of the assessee in the absence of any evidence. The CIT(A) discussed the said issue from pages 24 to 27 of the impugned order. We note that the assessee did not submit any reply to the satisfaction of both the authorities below that a new compound wall erected at any place o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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