2019 (12) TMI 516

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..... inst the order dated 30-08-2018 of ld. CIT(A)-1, Jaipur for the Assessment Year 2012-13 wherein the assessee has raised following grounds of appeal. ''Under the facts and circumstances of the case, the ld. CIT(A) has legally and factually erred in confirming addition of Rs. 5,04,843/-, kindly delete the same.'' 2.1 Brief facts of the case are that the assessee is an individual and filed the ret .....

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..... ce made by the AO. 2.3 Before the Tribunal, the ld.AR of the assessee contended that in the original confirmation filed before the AO the interest amount charged from each party was not specified and the assessee was not maintaining the books of account. However, before the ld. CIT(A) assessee filed the fresh confirmation letters from the borrowers showing interest amount charged from each party. .....

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..... to the assessment order for the Assessment Year 2013-14 passed u/s 143(3) as well as order of the ld. CIT(A) and submitted that interest expenditure to the interest income was allowed by the AO. The ld. CIT(A) has confirmed the order of the AO. The assessee challenged the part disallowance of interest. 2.4 On the other hand, the ld. DR relied on the orders of the authorities below and submitted t .....

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..... nterest expenditure to the extent of interest income received from various parties. Thus it appears that interest received by the assessee against these parties for the Assessment Year 2013-14 was accepted by the AO and corresponding interest was also allowed by the AO for which relevant portion of the assessment order at page 2 is reproduced as under:- ''2. In the reply dated 10-02-2016, it has .....

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..... e challenged the said action of the AO restricting the claim of deduction on account of interest expenditure to the interest income. However, the ld. CIT(A) while passing the order dated 19-12-2017 for the Assessment Year 2013-14 has confirmed the action of the AO. Accordingly, in view of the facts and circumstances of the case, the claim of interest expenditure of the assessee to the interest inc .....

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