PRANIDHI CONSTRUCTIONS PRIVATE LIMITED,KOLKATA V. ASSISTANT COMMISSSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RANCHI, RANCHI

ITA 98/RAN/2022

AI Insights

Pranidhi Constructions Private Limited appealed against the order of the CIT(A), Patna-3, which upheld the disallowance of interest on unsecured loans from 14 companies. The Assessing Officer initially disallowed these deductions, citing that the companies were inactive. However, the assessee provided evidence from the Ministry of Corporate Affairs (MCA) showing that all companies were active. The Assessing Officer, upon re-examination, confirmed the companies' active status but did not amend the assessment. The tribunal, after reviewing the submissions and the revised status of the companies, allowed the appeal, directing the Assessing Officer to permit the interest deductions.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 633155 (ITAT-RANCHI)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 11-06-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Assessment Year: 2018-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL, RANCHI BENCH, RANCHI BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER ITA No. 98/Ran/2022 (Assessment Year: 2018-19) Pranidhi Constructions Private Limited, 1, British India Street, Room No. 19, Old Block, Kolkata-700069. PAN No. AAECP 4445 R Vs. A.C.I.T., Central Circle-1, Ranchi. Appellant/ Assessee Respondent/ Revenue Assessee represented by Sri R.R. Mittal, A.R. Department represented by Shri Khub Chand Pandya, Sr.DR Date of hearing 11/06/2025 Date of pronouncement 11/06/2025 O R D E R PER: BENCH 1. This is an appeal filed by the assessee against the order of the learned CIT(A), Patna-3, Patna in appeal No. CIT(A), Patna-3/10307/2017-18 dated 30/09/2022 for the A.Y. 2018-19. 2. Shri R.R. Mittal, ld A.R. is represented on behalf of the assessee and Shri Khub Chand Pandya, ld. Sr.DR is represented on behalf of the revenue. 3. It was submitted by the ld. AR that in the course of assessment, the Assessing Officer had disallowed the interest paid on unsecured loans taken from 14 companies as mentioned in page No. 2 and 3 of the assessment order. It was a submission that the Assessing Officer had in para 3.1.2 of his order, held that the assessee company is found to have made transactions with the above said companies, whose registrations reported to have been cancelled by the Ministry of Corporate Affairs (MCA). The ld. Authorised Representative had placed before ITA No. 98/Ran/2022 Pranidhi Constructions P ltd. Vs ACIT 2 us the copies of the MCA certificates dated 05/06/2025 to show that all the 14 companies were active. The same were sent to the Assessing Officer for his comments and report. The Assessing Officer has replied to the same wherein he has mentioned that on examination of these documents and upon verifications of the records available on the official MCA website and it is found that all the 14 companies are currently active. It was a submission that the Assessing Officer himself has verified and found that the companies are active and the same finding goes against his findings in his assessment order, the addition as made by the Assessing Officer is liable to be deleted. It was a submission that the ld. CIT(A) had blindly confirmed the disallowance as made by the Assessing Officer. 4. In reply, the ld. Sr.DR has vehemently supported the orders of the Assessing Officer and the ld. CIT(A). 5. We have considered the rival submissions. As it is noticed from the report filed by the Assessing Officer that all the 14 companies are specifically found to be active and findings of the Assessing Officer in his assessment order in para 3.1.2 is erroneous. The Assessing Officer is directed to allow the interest paid on the unsecured loans in the hands of the assessee. 6. In the result, this appeal of the assessee is allowed. Order announced in open court on 11th June, 2025. Sd/- Sd/- (RATNESH NANDAN SAHAY) (GEORGE MATHAN) ACCOUNTANT MEMBER JUDICIAL MEMBER Ranchi, Dated: 11/06/2025 *Ranjan Copy to: ITA No. 98/Ran/2022 Pranidhi Constructions P ltd. Vs ACIT 3 1. Assessee 2. Revenue 3. CIT 4. DR By order 5. Guard File Sr. Private Secretary, ITAT, Ranchi "