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TMI Blog2025 (1) TMI 499X X X X Extracts X X X X X X X X Extracts X X X X ..... Sr. DR. ORDER PER SHAMIM YAHYA, AM : These appeals by the assessee are against the separate orders of the Ld. CIT(A)/NFAC, New Delhi both dated 09.12.2022 pertaining to assessment years 2015-16 & 2016-17 respectively. 2. The solitary ground raised in AY 2015-16 reads as under:- "That Ld. CIT(A)(NFAC) without appreciating the correct facts of the case is not justified in law and facts and cir ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the case are that the assessee has claimed interest expenses of Rs. 10,64,414/- on the unsecured loans of Rs. 142,00,000/-. From the perusal of the balance sheet, it was seen that the assessee has made net current investment of Rs. 3,77,25,000/- with M/s Indica Food Pvt. Ltd., but no income was shown by the assessee. Therefore, show cause was issued by the AO and the AO made the addition of Rs. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... one under section 14A read with Rule 8 and confirmed the addition made by the AO by dismissing the appeal of the assessee. 7. Aggrieved with the above, assessee appealed before the Ld. CIT(A). 8. We have heard both the parties and perused the records. We note that in this case assessee has not earned any exempt income and it is a well settled proposition that when any exempt income has not been ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ear 2016-17 is concerned, since the facts of the case are similar and identical to assessment year 2015-16 as aforesaid, hence, our aforesaid decision given for the assessment year 2015-16 shall apply mutatis mutandis to the assessment year 2016-17 as well. We hold and direct accordingly. As a result, the assessee's appeals for AYs 2016-17 also stand allowed.
Order pronounced on 08.01/2025. X X X X Extracts X X X X X X X X Extracts X X X X
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