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TMI Blog2019 (2) TMI 1704X X X X Extracts X X X X X X X X Extracts X X X X ..... ; Revenue by: Shri D.G. Pansari, D.R. ORDER Rajesh Kumar, The present appeal has been preferred by the assessee against the order dated 21.09.2016 of the Commissioner of Income Tax (Appeals) [hereinafter referred to as the CIT(A)] relevant to assessment year 2012-13. 2. The only issue raised by the assessee is against the confirmation of addition of Rs. 17,5 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bsp; which worked out to Rs. 27,70,713/- and added the same to the income of the assessee u/s 36(!)(iii) of the Act. 4. In the appellate proceedings, the ld CIT(A), after taking into account the contentions of the assessee partly allowed the appeal of the assessee by partly sustaining the addition to the tune of Rs. 17,58,421 by observing and holding as under:- "5.5. It is noted that lo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e advances against factory plots and advances to staff. Thus, the interest free advances not for business are the advances to directors and associates of Rs. 1,32,29,609/- Out of this the amount of Rs. 937,232/- is advance to Reliable Infrastructure P. Ltd. on which interest @10% has been booked. On the balance Rs. 1,22,92,377/- no interest is charged. A presumption can certainly be ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d advances to staff and the remaining amount of advances represented the advances to various govt. authorities. The ld CIT(A) has recorded a finding of facts to this effect and sustained the additions on Rs. 1,22,92,377/- @14% by excluding out the advances to directors of Rs. 1,32,29,609/- advance given to Reliable Infra Ltd Rs. 9,37232/-for business purpose. Thus the ld CIT(A) has acc ..... X X X X Extracts X X X X X X X X Extracts X X X X
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