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Ladhuram Toshniwal & Sons Pvt. Ltd. Vs. ACIT, CC-4(4), Kolkata

Case No: I.T.A. No. 659/Kol/2024
Court: Income Tax Appellate Tribunal (ITAT), Kolkata Bench
Date: 3/17/2025

Parties Involved

appellantLadhuram Toshniwal & Sons Pvt. Ltd.
respondentACIT, CC-4(4), Kolkata

Facts Summary

The assessee, Ladhuram Toshniwal & Sons Pvt. Ltd., filed its return of income for Assessment Year 2018-19 declaring a total income of Rs. 99,27,760/-. The case was selected for scrutiny, and notices under sections 143(2) and 142(1) were issued. The Assessing Officer (AO) passed an assessment order under section 143(3) determining the total income at Rs. 1,49,36,610/- by making two additions: interest on unsecured loan under section 36(1)(iii) of Rs. 35,88,850/- and disallowance of rent paid under section 40a(2)(b) of Rs. 5,20,000/-. Aggrieved by this order, the assessee appealed to the Commissioner of Income Tax (Appeals) [CIT(A)], who sustained the addition of Rs. 35,88,850/- but deleted the addition of Rs. 5,20,000/-. Dissatisfied, the assessee further appealed to the ITAT.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the addition of Rs. 35,88,850/- on account of interest on unsecured loan under section 36(1)(iii) is valid.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

1 precedent cited in this judgement.

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