Income Tax Appellate Tribunal Raipur Rajesh Kumar Goyal, Bhilai, Durg vs Deputy Commissioner Of Income Tax, ... on 6 March, 2024 आयकर अपीलीय अिधकरण, रायपुर यायपीठ, रायपुर IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH, RAIPUR ी र वश सूद, याियक सद य एवं ी अ ण खोड़ पया, लेखा सद य के सम । BEFORE SHRI RAVISH SOOD, JM & SHRI ARUN KHODPIA, AM (ITA No.8/RPR/2024) (Assessment Year:201415) Rajesh Kumar Goyal, Deputy Commissioner of Income Tax1(1), M/s Pooja Steels, 19, Lights Industrial Bhilai, New Civic Centre, Bhilai, Area, Bhilai, Distt. Durg (C.G.) (C.G.) PAN: ADBPG2456J (अपीलाथ /Appellant) . ( यथ / Respondent) . िनधा रती क ओर से /Assessee by : Shri Mulchand Jain, Adv. राज व क ओर से /Revenue by : Shri Satya Prakash Sharma, Sr. DR सुनवाई क तार ख / Date of Hearing : 21.02.2 024 घोषणा क तार ख/Date of : 06.03.2 024 Pronouncement आदे श / O R D E R Per Arun Khodpia, AM: The captioned appeal is filed against the order of Commissioner of Income Tax (Appeals, (In short, 'CIT(A)'), National Faceless Appeal Centre (NFAC) dated 13.11.2023 for the assessment year 201415, which in turn arose from the order u/s 144 r.w.s. 143(3) of the Income Tax Act, (In short 'The Act') framed by the Deputy Commissioner of Income Tax1(1), Bhilai (In short, 'The AO') dated 19.12.2016. 2. The grounds of appeal raised by the assessee are as under: 1. That, on the facts & the circumstances of the case the learned CIT(Appeals) has erred in maintaining disallowance of Rs. 398465/ of excess rate of interest (as per Ld. A.O.) paid to persons referred to in Sec. 2 ITA No. 8/RPR/2024 Rajesh Kumar Goyal 40 A(2)(b) out of total disallowance of Rs. 995199/ when the disallowance of same rate of interest has been deleted for other persons. Further the assessee had made several arguments for justification of rate of interest paid which were not considered. 2. That, on the facts & the circumstances of the case the learned CIT(Appeals) has erred in maintaining disallowance of interest for not charging of interest from one sister concern C.J. Ispat Pvt. Ltd. Whereas the assessee had ample capital of his own to provide financial assistance to company of which he was 50 % shareholder as well as director and also duty bound to protect the company and also looking to the fact that the same was old balance and the Ld. A.O. had not found any nexus between loans taken and advance made to the company. 3. That, on the facts & the circumstances of the case the learned CIT(Appeals) has erred in making disallowance of Rs. 70488/ out of sales commission whereas the assessee had provided all details & copy of particular bill. 4. That, on the facts & the circumstances of the case the learned CIT(Appeals) has erred in maintaining addition on account of stock valuation at Rs. 345079/ whereas the assessee has fully explained the basis of stock valuation with complete details & sample purchase bill. 5. That, on the facts & the circumstances of the case the learned CIT(Appeals) has erred in maintaining addition of Rs. 307000/as unexplained sources as follows 6. That, on the facts & the circumstances of the case the learned CIT(Appeals) has erred in maintaining disallowance of Rs. 75000/out of loading, unloading & cutting expenses for reason that the same was not contested in past & no evidence was provided whereas the assessee had provided tally C.D. to Ld. A.O. which he has clearly verified, and the ledger contained details which could be cross checked from tally data. Further this addition was not contested earlier since appeal was not preferred looking to quantum of disallowances. 3 ITA No. 8/RPR/2024 Rajesh Kumar Goyal 7. That, on the facts & the circumstances of the case the learned CIT(Appeals) has erred in maintaining disallowance of Rs. 75000/out of loading, unloading & cutting expenses for reason that the same was not contested in past & no evidence was provided whereas the assessee had provided tally C.D. to Ld. A.O. which he has clearly verified, and the ledger contained details which could be cross checked from tally data. Further this addition was not contested earlier since appeal was not preferred looking to quantum of disallowances. 8. That, on th