M/S TRADITIONAL GALLERY PVT. LTD.,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4, JAIPUR
In the result, appeals of the assessee are allowed
ITA 108/JPR/2019[2014-15]Status: DisposedITAT Jaipur12 May 2022AY 2014-15
For Appellant: Shri Manish Agarwal (CA)For Respondent: Smt. Runi Pal (Addl.CIT)
Section 143(3)Section 14ASection 36(1)(iii)
…on reliance is placed on the following judgments :- Shoorj Vallabh Das & Co. 46 ITR 144 (SC) Godhra Electricity Co. Ltd. vs. CIT 225 ITR 746 (SC) CIT vs. VTC Leasing & Finance Ltd. 39 TW 211 (Raj. HC) Brahmaputra Capital & Financial Services Ltd. vs. ITO 119 ITD 266 (Delhi) The ld. A/R further submitted that while making addition of Rs. 54,68,858/- on account of notional interest and disallowance of interest expenses of Rs. 2,62,306/- on account of loan advanced to Nav Sarjan Projects Pvt. Ltd. and S.D. Education Trust, the AO has completely ignored the vital fact that entire advances made were considered…