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2022 (12) TMI 536 - AT - Income TaxDisallowance of interest on account of unsecured loans - unsecured loan u/s. 68 - assessee to avail the scheme of direct taxes VSV Act 2020 - HELD THAT:- It is clear that the impugned unsecured loans were taken in A.Y. 2010-11 i.e. A.Y. 2009-10 and not during the year under consideration. It is worthwhile to note that in A.Y. 2009-10 these loans were accepted as genuine but since under the VSV Act 2020. The assessee had to settle the dispute in respect of the entire amount, therefore, the dispute relating the unsecured loans taken by the assessee has been settled under the VSV Act, 2020 which also included the impugned loans whose genuineness had already been accepted in earlier assessment years As in our considered opinion the CIT(A) could not have imputed the surrender under the VSV Act, 2020 and sustained the impugned disallowance of interest which was not part of the settlement of dispute under the VSV Act, 2020. Considering the facts of the case in totality in the light of the discussion herein above we direct the AO to delete the impugned disallowances of interest from the captioned assessment years.
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