SRS LTD.,FARIDABAD vs. DCIT, CENTRAL CIRCLE- II, FARIDABAD

ORDER Per Bench: The present appeals have been filed by the assessee against the orders of ld. CIT(A)-3, Gurgaon dated 30.11.2018 and 29.12.2018. 2. Since, the issue involved in & 1696/Del/2019 are similar, they were heard together and being adjudicated by a common order. In ITA No. 1695/Del/2019, following grounds have been raised by the assessee:

, 1696 & 1697/Del/2019 2 SRS Ltd.

2) That in any case and in any view of the matter, action of Ld. CIT(A) in confirming the reopening of the impugned assessment and framing of impugned assessment order are bad in law and against the fact and circumstance of the case. 3) That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. A.O. in making addition of Rs.56,96,60,500/- u/s 68 of the Income Tax Act, 1961 as unexplained credit and that too without proper appreciation of facts on record, and by recording incorrect facts and findings, and making allegations without any basis, material or evidence and merely on the basis of surmises and conjectures and without observing the principal of natural justice. 4) That in any case and in any view of the matter, action of Ld. CIT(A) in confirming the addition of Rs. Rs.56,96,60,500/- is bad in law and against the facts and circumstances of the case. 5) That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. A.O. in passing the impugned order without giving adequate opportunity of being heard and by not observing the principles of natural justice.”

“1) That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of the Ld. A.O. in making disallowance of Rs. 66,39,000/- being interest expenses claimed on the ground that interest bearing funds were allegedly utilized for advancing non-interest bearing loans & advances u/s 36(1)(iii) of the Income Tax Act. 2) That in any case and in any view of the matter, action of Ld. CIT(A) in confirming the disallowance of Rs.66,39,000/- is bad in law and against the facts and circumstances of the case. 3) That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in , 1696 & 1697/Del/2019 3 SRS Ltd. confirming the action of Ld. A.O. in passing the impugned order without giving adequate opportunity of being heard and by not observing the principles of natural justice.”