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2024 (10) TMI 1487

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..... e and expenditure booked on account of interest accrued and payable. The petitioner had availed certain interest-bearing loans, and at the same time, had also advanced unsecured loans. AO found that the interest payable in respect of certain loans advanced by the assessee was higher than the interest at which the funds were arranged. For the aforesaid reason, the assessee had made an addition bein .....

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..... this Court. Revenue fairly states that in the given circumstances, the matter may be remanded to the AO to consider the request of the petitioner for immunity from imposition of the penalty u/s 270AA afresh. This course commends to this Court. We, accordingly, set aside the impugned order passed by the AO u/s 270AA of the Act and remand the matter to the AO to consider afresh. - HON'BLE MR. .....

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..... case was one of under-reporting of income in consequence of mis-reporting . This was also noted by the AO in the impugned order. 4. The controversy relates to the income and expenditure booked on account of interest accrued and payable. The petitioner had availed certain interest-bearing loans, and at the same time, had also advanced unsecured loans. The AO found that the interest payable in respe .....

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..... n technical difficulties and was not able to do so. 7. It is noted that consequently, the impugned order has been passed without considering the contentions of the petitioner, as sought to be advanced before this Court. 8. The learned counsel appearing for the Revenue fairly states that in the given circumstances, the matter may be remanded to the AO to consider the request of the petitioner for i .....

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