TMI Blog2018 (12) TMI 1661X X X X Extracts X X X X X X X X Extracts X X X X ..... without having any fresh evidences nor pointing out what is the failure on the part of the assessee to truly and fully disclosed material facts required for his assessment. This being so, the reopening of the assessment itself is invalid. Even on merits, it is not disputed that interest receipt has been taxed. Once the interest receipt has been taxed, obviously the expenditure incurred in respect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Vijayaraghavan represented on behalf of the Assessee and Mr.Balina Suresh Babu represented on behalf of the Revenue. 3. It was submitted by ld.A.R that original assessment in the case of assessee came to be completed u/s.143(1) of the Act on 19.04.2014. Subsequently notice u/s.148 of the Act had been issued on 08.02.2010 beyond four years period for bringing to tax interest payment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed the interest paid on the ground that there was no business activity. It was a submission that as the assessee had borrowed funds, interest had to be paid. It was a submission that the principle was not being disputed, but only the interest payments on the loan taken has been disallowed, alleging no business activity. It was a prayer that the reopening itself is liable to be quashed and even on ..... X X X X Extracts X X X X X X X X Extracts X X X X
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