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2024 (5) TMI 1499

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..... which were responded by the parties by filing / furnishing all the documents as desired by the AO. Therefore we find merit in the contention of the assessee when the unsecured loans were not doubted for being nongenuine in the earlier assessment years how the corresponding interest on the said loans could be added u/s 68 - CIT(A) has erred in sustaining the addition - Decided in favour of assesse .....

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..... ts in brief are that the assessee filed return of income on 30.09.2013 declaring total income of Rs. 17,93,497/-. The case of the assessee was selected for scrutiny and accordingly the assessment u/s 143(3) was framed vide order dated 24.02.2015 assessing the income at Rs. 17,93,500/-. Thereafter the AO received information from DDIT(Inv), Unit-3(1), Kolkata and Central Circle-2(2), Kolkata that t .....

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..... of the assessee besides adding interest of Rs. 1,73,90,910/- in the assessment framed u/s 147 read with Section 144B of the Act dated 29.09.2021. 5. In the appellate proceedings, the Ld. CIT(A) partly allowed the appeal of the assessee by deleting the addition of Rs. 4,80,00,000/- and also part addition on account of interest amounting to Rs. 80,50,100/-(wrongly mentioned in the appellate order wa .....

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..... ans which were taken in the earlier assessment years. We note that even during the course of assessment proceedings the notices were issued to all the entities u/s 133(6) of the Act which were responded by the parties by filing / furnishing all the documents as desired by the AO. Therefore we find merit in the contention of the assessee when the unsecured loans were not doubted for being nongenuin .....

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