2023 (9) TMI 751

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..... ions filed by the assessee, alongwith supporting documents viz. ledger account produced before us for our perusal, we are hereby directing that the addition made by the AO may be deleted. No cogent reason has been furnished by the Assessing Officer for rejecting the rectification application filed by the assessee. Appeal of the assessee is allowed.
Smt. Annapurna Gupta, Accountant Member And Shri Siddhartha Nautiyal, Judicial Member For the Appellant : Shri S. N. Divatia, A.R. For the Respondent : Shri Ashok Kumar Suthar, Sr. D.R. ORDER PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER: This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax(Appeals), (in short "Ld. CIT(A)"), National Facele .....

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..... t there is a difference of interest income as reflected in Form No. 26AS (73,82,483/-) and the amount of interest income as declared in the books of account (70,56,333/-). Accordingly, the Assessing Officer added the difference of Rs. 3,26,150/- to the total income of the assessee under Section 56 of the Act under the head "income from other sources". 4. Thereafter, the assessee filed rectification application dated 30.12.2019 to the Assessing Officer in which it was contended that the assessee is having three different ledgers in which they have booked the interest income. However, during the course of assessment, the Assessing Officer took into consideration only one general ledger (interest received - other bank), however, the Assessing .....

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..... t that actual interest income amounting to Rs. 72 lakhs has been accounted for by the assessee as against the income of 70.56 lakhs stated to have been declared by the assessee as per the Assessing Officer. Accordingly, it was submitted that adding the aforesaid income would clearly amount to double taxation. 6. In response, Ld. D.R. relied that observations made by the Assessing Officer and CIT(A) in their respective orders. 7. On going through the facts of the case, we are in agreement with the Counsel for the assessee that the Assessing Officer did not take into consideration the other ledger account maintained by the assessee reflecting interest income of Rs. 2,07,007/-. Accordingly, in view of the arguments made before us and the Rec .....

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