DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.-3, SURAT vs. SH. HARESHBHAI MOHANBHAI SAKARIYA, SURAT
In the result, Revenue’s appeal is dismissed
ITA 48/SRT/2021[2017-18]Status: DisposedITAT Surat25 May 2022AY 2017-18
Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A No.01/Srt/2021 (Ay 2010-11) It(Ss)A No.09/Srt/2020 (Ay 2014-15) (Hearing In Physical Court) Deputy Commissioner Of Shri Dineshchandra D Income-Tax, Central Circle- Koradia, 3Room No.507, 5Th Floor, 9/10, Dayanand Society, Aayakar Bhawan, Majura B/H.Navyug College, Gate, Surat-395001 Rander Road, Surat Pan No: Acupk 3696 A Assistant Commissioner Of Vs Income-Tax, Central Circle-3, Room No.507, 5Th Floor, Aayakar Bhawan, Majura Gate, Surat-395001 Appellant / Revenue Respondent /Assessee
Section 132Section 132(1)Section 143(3)Section 14ASection 153ASection 153CSection 158BSection 254(1)
4%. The Assessing Officer on the basis of his observation made disallowance of difference i.e., @ 3% and worked out the same at Rs.22,06,072/-. Before Ld. CIT(A), the assessee submitted that there is no direct nexus between the interest bearing loans with that of loan advanced by assessee. Most of the loans were advanced prior to assessment year