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TMI Blog2024 (5) TMI 1499X X X X Extracts X X X X X X X X Extracts X X X X ..... AJESH KUMAR, AM: This is the appeal preferred by the assessee against the order of the Ld. Commissioner of Income Tax (Appeals)-NFAC, Delhi (hereinafter referred to as the Ld. CIT(A)"] dated 08.11.2023 for the AY 2013-14. 2. In ground no. 1 to 6, the assessee has challenged the reopening of assessment u/s 147 read with Section 148 of the Act which was not pressed at the time of hearing and accor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1 and also debited interest of Rs. 1,17,230/- on that accommodation entry. Consequently after recording reason to believe u/s 148(2) of the Act, the case was reopened u/s 147 by issuing notice u/s 148 of the Act on 4.3.2012. The assessee filed various details/information as directed by AO during the course of assessment proceedings in respect of unsecured loans of Rs. 4,80,00,000/- received from v ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . 4,80,00,000/- was already examined by the AO during the assessment proceedings which culminated u/s 143(3) of the Act and therefore the addition of Rs. 4,80,00,000/- and interest of Rs. 80,50,500/- were deleted by the Ld. CIT(A) by holding that the corresponding unsecured loans were already accepted in the preceding and succeeding assessment years and therefore the interest cannot be disallowed ..... X X X X Extracts X X X X X X X X Extracts X X X X
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