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Sh. Magendra Singh Rathore vs. The ACIT and DCIT

Case No: ITA No. 460/JPR/2024 and ITA No. 483/JPR/2024
Court: Income Tax Appellate Tribunal, Jaipur
Date: 9/23/2024

Parties Involved

appellantSh. Magendra Singh Rathore
respondentThe ACIT, Central Circle-2, Jaipur
respondentThe DCIT, Central Circle-2, Jaipur

Facts Summary

The case involves two appeals filed by Sh. Magendra Singh Rathore against orders passed by the Assessing Officer under section 143(3) of the Income Tax Act for the assessment years 2016-17 and 2017-18. The assessee challenged the disallowance of interest expenditure, denial of deductions under Chapter VI-A, and the charging of interest under sections 234A and 234B of the Act. The assessee argued that the interest expenditure was incurred wholly and exclusively for the purpose of earning interest income and that the disallowance was contrary to the provisions of law and facts. The assessee also claimed that the disallowance of deductions under Chapter VI-A was not substantiated by documentary evidence. The Tribunal allowed the appeals in part, disallowing the excess interest paid by the assessee and allowing the deductions under Chapter VI-A.

Decision in favour of

Assessee

Legal Issues

  • 1. Disallowance of interest expenditure under section 57(iii) of the Act
  • 2. Denial of deductions under Chapter VI-A

Judgment Outcome

Decided in favour of Assessee.

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Sh. Magendra Singh Rathore vs. The ACIT and DCIT | ITA No. 460/JPR/2024 and ITA No. 483/JPR/2024 | 2024 | Opakhya