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2021 (5) TMI 897 - AT - Income TaxDisallowance u/s. 40A(3) - HELD THAT:- Since the amounts are in the nature of reimbursement, not debited to P&L account of the assessee, no disallowance u/s. 40A(3) is called for. Addition on account of seized material - HELD THAT:- As argued that the name, address, PAN number, bank statement, details of debit, credit and details regarding the refund of the amounts have been duly submitted before the revenue authorities. The amount has been received on 07.03.2007, repaid on 11.06.2007 even before the date of search i.e. 15.11.2007, it can be considered as a business loan received and the same has been duly refunded. We have also perused the record before us and find that there is no material to prove that the amount received is liable for tax u/s. 68 and the addition made by the AO is directed to be deleted. Addition made on account of PDC and notional interest - HELD THAT:- Since, the issue of PDC has already been dealt on merits of the case, we hereby hold that no notional interest on such amount can be upheld. The interest calculated on the PDC by the AO is without any basis or evidence. Hence, we direct the addition made by the AO be deleted.
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