DCIT-42(1)(1), MUMBAI V. SHRI SATYENDRA KUMAR TRILOKNATH GOYAL, MUMBAI

ITA 1113/MUM/2025

AI Insights

The case involves an appeal by the Revenue against the order of the Ld. Commissioner of Income-tax (Appeals) which had deleted the additions made by the Assessing Officer on the grounds of unsecured loans, unexplained expenditure, and interest expenses for the assessment year 2013-14. The assessee, Satyendra Kumar Triloknath Goyal, proprietor of M/s Peerless Construction, had received loans which the Revenue contended were accommodation entries. The Tribunal examined the evidence including loan confirmations, bank statements, and previous assessments, and found that the assessee had discharged the burden of proof regarding the loans. Consequently, the Tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s decision.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 713249 (ITAT-MUMBAI)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 31-07-2025
• Appeal Filed By: Department
• Order Result: Dismissed
• Assessment Year: misc
• Other Referred Cases: DCIT (CC) vs. M/s Jainam Investments, DCIT 25(1) vs. M/s YRV International, Shri Ashok Nagraj Mehta vs. ACIT Circle 19(1), Asst CIT vs. Shri Dilip Chimanlal Gandhi, Jitendra M Kitawat vs. ITO, Smt. Ritu Kamal Singal vs. ITO
• Laws Referred To: Income-tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: VIRABHADRA S. MAHAJAN
• Assessee Lawyers: AJAY R. SINGH; AKSHAY PAWAR
• Keywords: Unexplained cash credit; Unexplained expenditure; TDS; Accommodation entries; Bogus
• Section: 143(3); 68; 133(6); 69C

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “C” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER) ITA No. 1113/MUM/2025 Assessment Year: 2013-14 DCIT 42(1)(1), Room No. 732, 7th floor, Kautilya Bhavan, BKC Mumbai-400051. Vs. Satyendra Kumar Triloknath Goyal, I 702, Pranay Nagar Society, Ram Mandir Extn Road, Vazira Naka, Borivali West, Mumbai-400091. PAN NO. AAEPG 3578 R Appellant Respondent Assessee by : Mr. Ajay R. Singh & Mr. Akshay Pawar Revenue by : Mr. Virabhadra S. Mahajan, Sr. DR Date of Hearing : 12/06/2025 Date of pronouncement : 31/07/2025 ORDER PER OM PRAKASH KANT, AM This appeal by the Revenue is directed against order dated 09.07.2024 passed by the Ld. Commissioner of Income-tax (Appeals) – National Faceless Appeal Centre, Delhi [in short ‘the Ld. CIT(A)’] for assessment year 2013-14, raising following grounds: 1. On the facts and circumstances of the case and in law, the Ld.CIT(A) erred in deleting the addition made of Rs. Printed from counselvise.com 1,75,00,000/ 1961 by the AO in respect of unsecured loans taken by the assessee from Bhanwarlal Jain who is an accommodation entry provider. 2. On the fact Ld.CIT(A) erred in deleting the addition made of Rs.5,25,000/ as unexplained expenditure u/s.69C of the I.T.Act, 1961 by AO in respect of commission paid on the said loans. 3. On the facts and circumstances Ld.CIT(A) erred in deleting the addition made of Rs.48,48,355/ (Rs. 38,86,191/ interest expenses on 2. Briefly stated, facts of the case are that the assessee is an individual and proprietor of M/s Peerless Construction, engaged in business of constructing buildings. The assessee filed his return of income on 28.09.2013 declaring total income of Rs.67,11,53 The return of income filed by the assessee was selected for scrutiny and statutory notices under the Act’) were issued and complied with. The assessment u/s 143(3) of the Act was completed on 26.02.2016 determining Rs.2,96,94,882/- by way of making three additions, firstly for unsecured loan of Rs.1,75,00,000/ credit u/s 68 of the Act, secondly, the loans were held as accommodation entry and therefore, commission pa Rs.5,25,000/- for obtaining such accommodation entry was held as unexplained expenditure u/s 69C of the Act, thirdly, the interest Rs.48,48,355/- in respect of current year loan Satyendra Kumar Triloknath ITA No. 1113/MUM/2025 1,75,00,000/- as unexplained cash credit u/s.68 of the I.T.Act, 1961 by the AO in respect of unsecured loans taken by the assessee from Bhanwarlal Jain who is an accommodation entry provider. 2. On the facts and circumstances of the case and in law, the Ld.CIT(A) erred in deleting the addition made of Rs.5,25,000/ as unexplained expenditure u/s.69C of the I.T.Act, 1961 by AO in respect of commission paid on the said loans. 3. On the facts and circumstances of the case and in law, the Ld.CIT(A) erred in deleting the addition made of Rs.48,48,355/ (Rs. 38,86,191/- + Rs. 9,62,164/-) by the AO on account of interest expenses on the said loans. Briefly stated, facts of the case are that the assessee is an individual and proprietor of M/s Peerless Construction, engaged in business of constructing buildings. The assessee filed his return of income on 28.09.2013 declaring total income of Rs.67,11,53 The return of income filed by the assessee was selected for scrutiny and statutory notices under the Income-tax Act, 1961 (in short ‘the were issued and complied with. The assessment u/s 143(3) of was completed on 26.02.2016 determining by way of making three additions, firstly for unsecured loan of Rs.1,75,00,000/- held as unexplained cash credit u/s 68 of the Act, secondly, the loans were held as accommodation entry and therefore, commission pa for obtaining such accommodation entry was held as unexplained expenditure u/s 69C of the Act, thirdly, the interest in respect of current year loan held Satyendra Kumar Triloknath Goyal 2 ITA No. 1113/MUM/2025 as unexplained cash credit u/s.68 of the I.T.Act, 1961 by the AO in respect of unsecured loans taken by the assessee from Bhanwarlal Jain who is an accommodation s and circumstances of the case and in law, the Ld.CIT(A) erred in deleting the addition made of Rs.5,25,000/- as unexplained expenditure u/s.69C of the I.T.Act, 1961 by AO of the case and in law, the Ld.CIT(A) erred in deleting the addition made of Rs.48,48,355/- ) by the AO on account of Briefly stated, facts of the case are that the assessee is an individual and proprietor of M/s Peerless Construction, engaged in business of constructing buildings. The assessee filed his return of income on 28.09.2013 declaring total income of Rs.67,11,530/-. The return of income filed by the assessee was selected for scrutiny tax Act, 1961 (in short ‘the were issued and complied with. The assessment u/s 143(3) of was completed on 26.02.2016 determining total income at by way of making three additions, firstly, addition held as unexplained cash credit u/s 68 of the Act, secondly, the loans were held as accommodation entry and therefore, commission paid of for obtaining such accommodation entry was held as unexplained expenditure u/s 69C of the Act, thirdly, the interest of held as unexplained Printed from counselvise.com as well as brought forward loans which were held was treated as unexplained expenditure u/s 69C of the Act. 3. On further appeal, the Ld. CIT(A) deleted the addition on the decision of the Co of the assessee for assessment year 2012 Revenue is in appeal before us, by way of raising grounds as reproduced above. 4. We have heard rival submissions of the parties and perused the relevant materials on record allegation are that assessee had rec the unsecured loans from the entities controlled and operated by Shri Bhawarlal Jain, i.e. an the course of assessment proceedings, the notice u/s 133(6) of the Act assessee received loans. In response, those parties confirmed loan given to the assessee and also filed copy of their bank statements. The assessee also filed his bank statement and further explained that loans were repai deducted on the interest payment regularly. The Ld. CIT(A) that in the additions Officer on similar allegation of the receipt of unsecured loan by way of accommodation entry from the Bhawarlal Jain but the Co ordinate Bench of the Tribunal Satyendra Kumar Triloknath ITA No. 1113/MUM/2025 as well as brought forward loans which were held as unexplained was treated as unexplained expenditure u/s 69C of the Act. On further appeal, the Ld. CIT(A) deleted the addition on the decision of the Co-ordinate Bench of the Tribunal in the case of the assessee for assessment year 2012-13. Revenue is in appeal before us, by way of raising grounds as We have heard rival submissions of the parties and perused the relevant materials on record. In the case of the assessee allegation are that assessee had received accommodation entry of the unsecured loans from the entities controlled and operated by , i.e. an accommodation entry provider. During the course of assessment proceedings, the Assessing Officer notice u/s 133(6) of the Act to all such parties from whom, the assessee received loans. In response, those parties confirmed loan to the assessee and also filed copy of their bank statements. The assessee also filed his bank statement and further explained that loans were repaid through account payee cheques and tax was deducted on the interest payment regularly. The Ld. CIT(A) s were made in earlier year by the Assessing Officer on similar allegation of the receipt of unsecured loan by way odation entry from the Bhawarlal Jain but the Co ordinate Bench of the Tribunal after verification of Satyendra Kumar Triloknath Goyal 3 ITA No. 1113/MUM/2025 as unexplained, was treated as unexplained expenditure u/s 69C of the Act. On further appeal, the Ld. CIT(A) deleted the additions relying ordinate Bench of the Tribunal in the case Aggrieved, the Revenue is in appeal before us, by way of raising grounds as We have heard rival submissions of the parties and perused . In the case of the assessee eived accommodation entry of the unsecured loans from the entities controlled and operated by accommodation entry provider. During Assessing Officer issued to all such parties from whom, the assessee received loans. In response, those parties confirmed loan to the assessee and also filed copy of their bank statements. The assessee also filed his bank statement and further explained d through account payee cheques and tax was deducted on the interest payment regularly. The Ld. CIT(A) observed by the Assessing Officer on similar allegation of the receipt of unsecured loan by way odation entry from the Bhawarlal Jain but the Co- after verification of documents of Printed from counselvise.com identity, confirmation, bank statements etc discharged his onus finding of the Co-ordinate Bench of the Tribunal in ITA No. 5562/Mum/2017 for assessment year 2012 under: “7. We have heard the rival submissions and perused the relevant material on record. The reasons for our decisions are given below. In the case of DR, it is held that \"where the AO made addition to assessee's income various parties, since the assessee failed to prove that any of those creditors had financial strength to lend such huge sums of money to assessee, that too without any collateral security, without interest and without a loan agreement, impugn In the case of by the Ld. DR, the AO had issued summons to the representatives of the investor companies. Despite th summons having been served, nobody appeared on behalf of any of the investor companies. The Department only received submissions through dak, which created a doubt about the identity of the investor companies. Thereafter, the AO independently got field e conducted with respect to the identity and creditworthiness of the investor companies and to examine the genuineness of the transaction. Enquiries were made at Mumbai, Kolkata and Guwahati, where these Companies were stated to be situated. On the basis of the detailed enquiries conducted, the AO held Assessment Year: 2012 to prove the existence of the identity of the investor companies and genuineness of the transaction. As mentioned earlier, in the instant case the of the AO was on the modus operandi adopted by Satyendra Kumar Triloknath ITA No. 1113/MUM/2025 identity, confirmation, bank statements etc held that assessee onus of burden u/s 68 of the Act. ordinate Bench of the Tribunal in ITA No. 5562/Mum/2017 for assessment year 2012-13 is reproduced as 7. We have heard the rival submissions and perused the relevant material on record. The reasons for our decisions are given below. In the case of Bikram Singh (supra), relied on by the Ld. DR, it is held that \"where the AO made addition to assessee's income u/s 68 in respect of loan taken from various parties, since the assessee failed to prove that any of those creditors had financial strength to lend such huge sums of money to assessee, that too without any collateral security, without interest and without a loan agreement, impugned addition deserves to be confirmed\". In the case of NRA Iron & Steel Pvt. Ltd. (supra), relied on by the Ld. DR, the AO had issued summons to the representatives of the investor companies. Despite th summons having been served, nobody appeared on behalf of any of the investor companies. The Department only received submissions through dak, which created a doubt about the identity of the investor companies. Thereafter, the AO independently got field enquiries conducted with respect to the identity and creditworthiness of the investor companies and to examine the genuineness of the transaction. Enquiries were made at Mumbai, Kolkata and Guwahati, where these Companies were stated to be situated. On the basis of the detailed enquiries conducted, the AO held Assessment Year: 2012-13 that the assessee had failed to prove the existence of the identity of the investor companies and genuineness of the transaction. As mentioned earlier, in the instant case the entire focus of the AO was on the modus operandi adopted by Satyendra Kumar Triloknath Goyal 4 ITA No. 1113/MUM/2025 held that assessee u/s 68 of the Act. The relevant ordinate Bench of the Tribunal in ITA No. 13 is reproduced as 7. We have heard the rival submissions and perused the relevant material on record. The reasons for our decisions (supra), relied on by the Ld. DR, it is held that \"where the AO made addition to n taken from various parties, since the assessee failed to prove that any of those creditors had financial strength to lend such huge sums of money to assessee, that too without any collateral security, without interest and without a loan ed addition deserves to be confirmed\". (supra), relied on by the Ld. DR, the AO had issued summons to the representatives of the investor companies. Despite the summons having been served, nobody appeared on behalf of any of the investor companies. The Department only received submissions through dak, which created a doubt about the identity of the investor companies. nquiries conducted with respect to the identity and creditworthiness of the investor companies and to examine the genuineness of the transaction. Enquiries were made at Mumbai, Kolkata and Guwahati, where these Companies were stated to be situated. On the basis of the detailed enquiries conducted, the AO held 13 that the assessee had failed to prove the existence of the identity of the investor entire focus of the AO was on the modus operandi adopted by Printed from counselvise.com Bhanwarlal Jain Group of cases to provide bogus accommodation entries of loan. The main reason of the AO for making addition information provided by the Investigation Wing of the Department. No independent enquiry has been conducted by the AO as was done in (supra). In the case of was unable to establish the identity, creditworthiness and genuineness of the said persons and transactions. As recorded by the Ld. CIT (A), during the course of assessment pro AO (i) loan confirmations from lenders, (ii) PAN of the lenders, (iii) copy of the return of income of lenders, who advanced the loan, (iv) copy of bank account of lenders (v) copy of bank account of the assessee and balance sheet and P & L account of the lenders. Therefore, the instant case is distinguishable from the above case laws relied on by the Ld. DR. 7.1 It is well settled that in order to discharge the onus u/s 68, the assessee must prove the following: (i) the identity of the creditor, (ii) the capacity of the creditor to advance money; and Assessment Year: 2012 (iii) the genuineness of the transaction. After the assessee has adduced ev prima facie the aforesaid, the onus shifts to the department. In the instant case, though the onus shifted to the department, the AO has failed to make necessary enquiry to reject the contentions of the assessee. In view of the above f we uphold the order of the Ld. CIT (A). 8. In the result, appeal filed by the revenue is dismissed. Satyendra Kumar Triloknath ITA No. 1113/MUM/2025 Bhanwarlal Jain Group of cases to provide bogus accommodation entries of loan. The main reason of the AO for making addition u/s 68 was on the b information provided by the Investigation Wing of the Department. No independent enquiry has been conducted by the AO as was done in NRA Iron & Steel Pvt. Ltd. In the case of Bikram Singh (supra), the assessee was unable to establish the identity, creditworthiness and genuineness of the said persons and transactions. As recorded by the Ld. CIT (A), during the course of assessment proceedings, the assessee filed before the AO (i) loan confirmations from lenders, (ii) PAN of the lenders, (iii) copy of the return of income of lenders, who advanced the loan, (iv) copy of bank account of lenders (v) copy of bank account of the assessee and (vi) copy of balance sheet and P & L account of the lenders. Therefore, the instant case is distinguishable from the above case laws relied on by the Ld. DR. 7.1 It is well settled that in order to discharge the onus , the assessee must prove the following: (i) the identity of the creditor, (ii) the capacity of the creditor to advance money; and Assessment Year: 2012-13 (iii) the genuineness of the transaction. After the assessee has adduced evidence to establish prima facie the aforesaid, the onus shifts to the department. In the instant case, though the onus shifted to the department, the AO has failed to make necessary enquiry to reject the contentions of the assessee. In view of the above factual matrix and position of law, we uphold the order of the Ld. CIT (A). 8. In the result, appeal filed by the revenue is dismissed. Satyendra Kumar Triloknath Goyal 5 ITA No. 1113/MUM/2025 Bhanwarlal Jain Group of cases to provide bogus accommodation entries of loan. The main reason of the was on the basis of information provided by the Investigation Wing of the Department. No independent enquiry has been conducted NRA Iron & Steel Pvt. Ltd. (supra), the assessee was unable to establish the identity, creditworthiness and genuineness of the said persons and transactions. As recorded by the Ld. CIT (A), during the course of ceedings, the assessee filed before the AO (i) loan confirmations from lenders, (ii) PAN of the lenders, (iii) copy of the return of income of lenders, who advanced the loan, (iv) copy of bank account of lenders (vi) copy of Therefore, the instant case is distinguishable from the 7.1 It is well settled that in order to discharge the onus (ii) the capacity of the creditor to advance money; and idence to establish prima facie the aforesaid, the onus shifts to the department. In the instant case, though the onus shifted to the department, the AO has failed to make necessary actual matrix and position of law, 8. In the result, appeal filed by the revenue is dismissed.” Printed from counselvise.com 4.1 We find that the Co relied on the following decision of the Co 1 ITANo. 6099/Mum/2016 DCIT (CC) Jainam Investments 2. ITANo. 1414/Mum/2017 DCIT 25(1) vs. M/s YRV International 3. ITA No. 2100/Mum/2016 and ITANo. 1645/Mum/2017 Circle 19(1) 4. ITANo. 7049/Mum/2016 Asst CIT Dilip Chimanlal Gandhi 5. ITA No. 7049 & 7050/Mum/2016 Jitendra M Kitawat vs. ITO 18(1X5) 6. ITANo. 7047/Mum/2016 Jitendra M Kitawat (HUF) vs. ITO 18(1)(5) 7. ITA No. 3017/Mum/2018 Smt. Ritu Kamal Singal vs. ITO 4.2 Before documents identical to which had been filed in earlier year had been filed. been taken , the unsecured loan giver Diamonds’ and ‘Naukar India parties for assessment year 2012 favour of the assessee by the Co identical documents have been filed in respect of parties to justify the discharging of onus the Ld. CIT(A) on the issue in dispute in respect of addition of the Satyendra Kumar Triloknath ITA No. 1113/MUM/2025 We find that the Co-ordinate Bench(supra) relied on the following decision of the Co-ordinate Bench : ITANo. 6099/Mum/2016 DCIT (CC)-l(3)vs. M/s Jainam Investments ITANo. 1414/Mum/2017 DCIT 25(1) vs. M/s YRV International ITA No. 2100/Mum/2016 and ITANo. 1645/Mum/2017 Shri Ashok Nagraj Mehta vs. ACIT Circle 19(1) ITANo. 7049/Mum/2016 Asst CIT-19(1) vs. Shri Dilip Chimanlal Gandhi ITA No. 7049 & 7050/Mum/2016 Jitendra M Kitawat vs. ITO 18(1X5) ITANo. 7047/Mum/2016 Jitendra M Kitawat (HUF) vs. ITO 18(1)(5) ITA No. 3017/Mum/2018 Smt. Ritu Kamal Singal vs. ITO 21(3114) Before documents identical to which had been filed in earlier year had been filed. Out of the list of parties from whom loans have unsecured loan giver parties namely Naukar India’ are also appearing in the list of the parties for assessment year 2012-13 which has been allowed in favour of the assessee by the Co-ordinate Bench (supra). Since identical documents have been filed in respect of parties to justify onus u/s 68 of the Act, we uphold the finding of the Ld. CIT(A) on the issue in dispute in respect of addition of the Satyendra Kumar Triloknath Goyal 6 ITA No. 1113/MUM/2025 while deciding ordinate Bench : Shri Ashok Nagraj Mehta vs. ACIT ITANo. 7047/Mum/2016 Jitendra M Kitawat (HUF) Before documents identical to which had been filed in earlier Out of the list of parties from whom loans have parties namely ‘Naukar are also appearing in the list of the 13 which has been allowed in ordinate Bench (supra). Since identical documents have been filed in respect of parties to justify u/s 68 of the Act, we uphold the finding of the Ld. CIT(A) on the issue in dispute in respect of addition of the Printed from counselvise.com unsecured loan. Thebground No. 1 of the appeal of Revenue is dismissed. 4.2 As far as addition of the commission expenses is concerned same is in respect of unsecured loans cash credits, which have already deleted have upheld said deletion while adjudicating ground no. 1 of appeal, therefore, consequent addition for the commission in respect of those entries is also de appeal is dismssed. 4.3 In respect of ground No. 3, the Ld. Counsel for the assessee has given list of the interest in respect of parties for the current year as well as the brought forward and in re where the loan has been allowed by the ITAT or the Ld. CIT(A) against which no appeal is pending. The relevant detail of the interest payment is reproduced as under: SR. NO. NAME, ADDRESS AND PAN OF THE LOAN CREDITORS 1 Navkar India 2 Rajan Diamonds 3 Mohit Enterprises Satyendra Kumar Triloknath ITA No. 1113/MUM/2025 Thebground No. 1 of the appeal of Revenue is As far as addition of the commission expenses is concerned s in respect of unsecured loans considered as unexplained which have already deleted by the ld CIT(A) and we have upheld said deletion while adjudicating ground no. 1 of therefore, consequent addition for the commission in those entries is also deleted. The ground No. 2 of the In respect of ground No. 3, the Ld. Counsel for the assessee has given list of the interest in respect of parties for the current year as well as the brought forward and in remark column given where the loan has been allowed by the ITAT or the Ld. CIT(A) against which no appeal is pending. The relevant detail of the interest payment is reproduced as under: , ADDRESS AND PAN OF THE LOAN INTEREST (Incl. TDS) TDS Rs. 218,137 Rs. 21,819 Loan allowed in appeal AY 12 1,344,000 134,400 Loan allowed by CIT(A) in AY 2009 AY 12 120,000 12,000 Loan allowed in Appeal AY 12 Satyendra Kumar Triloknath Goyal 7 ITA No. 1113/MUM/2025 Thebground No. 1 of the appeal of Revenue is As far as addition of the commission expenses is concerned considered as unexplained by the ld CIT(A) and we have upheld said deletion while adjudicating ground no. 1 of therefore, consequent addition for the commission in leted. The ground No. 2 of the In respect of ground No. 3, the Ld. Counsel for the assessee has given list of the interest in respect of parties for the current mark column given where the loan has been allowed by the ITAT or the Ld. CIT(A) against which no appeal is pending. The relevant detail of the Remarks Loan allowed in appeal AY 12-13 by ITAT Loan allowed by CIT(A) in AY 2009-10 and ITAT in AY 12-13 Loan allowed in Appeal AY 12-13 by ITAT Printed from counselvise.com 4 Mukti Exports 5. Pushpak Gems S Navkar Diamond 7 Mehul Gems Pvt Ltd 8 Daksh Diamonds 9 Jewel Diam 10 Kothari & Co. 11 Minal Gems 12 Rose Impex Total interest disallowed 4.3 Since the loans corresponding to the interest paid has already been allowed either by the Co CIT(A) and no appeal has been preferred against said finding of CIT(A), therefore, the interest paid in respect of those loans also stands allowed. We uphold the finding of ld CIT(A) on the issue in dispute. The ground No. 3 of the appeal of the Revenue is accordingly dismissed. Satyendra Kumar Triloknath ITA No. 1113/MUM/2025 120,000 12,000 Loan allowed in Appeal AY 12 360,000 36,000 Loan allowed in Appeal AY 12 380,054 38,005 Loan allowed in Appeal AY 12 Mehul Gems Pvt Ltd 120,000 12,000 Loan allowed in Appeal AY 12 324,000 32,400 Loan allowed by CIT (A) in AY 2009 in AY 12 120,000 12,000 Loan allowed by CIT (A) in AY 2009 in AY 12 120,000 12,000 Loan allowed by CIT (A) in AY 2009 in AY 12 360,000 36,000 Loan allowed by CIT (A) in AY 2009 in AY 12 300,000 30,000 Loan allowed by CIT (A) in AY 2009 in AY 12 interest disallowed 3,886,191 388,624 Since the loans corresponding to the interest paid has already been allowed either by the Co-ordinate Bench of the ITAT or the Ld. and no appeal has been preferred against said finding of therefore, the interest paid in respect of those loans also We uphold the finding of ld CIT(A) on the issue in The ground No. 3 of the appeal of the Revenue is accordingly dismissed. Satyendra Kumar Triloknath Goyal 8 ITA No. 1113/MUM/2025 Loan allowed in Appeal AY 12-13 by ITAT Loan allowed in Appeal AY 12-13 by ITAT Loan allowed in Appeal AY 12-13 by ITAT Loan allowed in Appeal AY 12-13 by ITAT Loan allowed by CIT (A) in AY 2009-10 and ITAT in AY 12-13 Loan allowed by CIT (A) in AY 2009-10 and ITAT in AY 12-13 Loan allowed by CIT (A) in AY 2009-10 and ITAT in AY 12-13 Loan allowed by CIT (A) in AY 2009-10 and ITAT in AY 12-13 Loan allowed by CIT (A) in AY 2009-10 and ITAT in AY 12-13 Since the loans corresponding to the interest paid has already ordinate Bench of the ITAT or the Ld. and no appeal has been preferred against said finding of therefore, the interest paid in respect of those loans also We uphold the finding of ld CIT(A) on the issue in The ground No. 3 of the appeal of the Revenue is Printed from counselvise.com 5. In the result, the appeal of the Revenue i Order pronounced in the open Court on Sd/- (RAJ KUMAR CHAUHAN JUDICIAL MEMBER Mumbai; Dated: 31/07/2025 Rahul Sharma, Sr. P.S. Copy of the Order forwarded to 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file. //True Copy// Satyendra Kumar Triloknath ITA No. 1113/MUM/2025 In the result, the appeal of the Revenue is dismissed. nounced in the open Court on 31/07/2025. Sd/ RAJ KUMAR CHAUHAN) (OM PRAKASH KANT JUDICIAL MEMBER ACCOUNTANT MEMBER Copy of the Order forwarded to : BY ORDER, (Assistant Registrar) ITAT, Mumbai Satyendra Kumar Triloknath Goyal 9 ITA No. 1113/MUM/2025 s dismissed. /07/2025. Sd/- OM PRAKASH KANT) ACCOUNTANT MEMBER BY ORDER, (Assistant Registrar) ITAT, Mumbai Printed from counselvise.com "