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2023 (5) TMI 117 - AT - Income TaxDisallowance of transport expense - HELD THAT:- As assessee has provided PAN of the transporter and the details of transport expenses. The genuineness of said expense is not doubted either by Assessing Officer or Ld. CIT(A). As per Section 194C(6) that the assessee has provided PAN of the transporter and the transaction is not disputed and no disallowances of such transport expense is warranted. Similarly, the view taken in the case of South India Freight Carriers [2019 (12) TMI 363 - ITAT BANGALORE]. Interest disallowance on account of interest paid to three parties - As find that assessee has filed copy of ITR of recipients of the interest along with certificate of Chartered Accountant as required Rule 31ACB in Form 26A. Therefore, this part of ground is allowed subject to verification by Assessing Officer. This part ground of assessee is allowed in above terms. Disallowance of machines salary expense - assessee submits that Assessing Officer disallowed 20% of machine salary expenses, which was restricted to 10% by Ld. CIT(A) - assessee further submits that lower authorities disallowed the expense without doubting genuineness of such expenses and assessee filed cash book for such expense - HELD THAT:- As assessee has shown expense of Rs.24.69 lakh, which was paid in cash and no justification was given before AO. AO reasonably disallowed only 20%. The Ld. CIT(A) further reduced it to 10%, thereby granted further relief of 50%. Entire expense assessee has shown in cash. Therefore, no reason to interfere with the finding of Ld. CIT(A). This ground of assessee’s appeal is dismissed. Disallowance of interest expense u/s 57 - assessee submits that Assessing Officer made addition by taking view that assessee has not furnished any details and Ld. CIT(A) confirmed the action of Assessing Officer by holding that no certificate as per Rule 31ACB in Form 26A is furnished - HELD THAT:- As the assessee failed to prove the nexus between the interest income offered in the return of interest expense made. Thus, this ground of appeal is dismissed.
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