Regunathan Venkata Rajendran v. ACIT (2020) 81 ITR 71 (SN) ( Bang) (Trib)

S. 250 : Appeal – Commissioner (Appeals) –Challenging entire Additions- Commissioner (Appeals) Considering only two out of seven items — Matter remanded to Commissioner (Appeals) to decide afresh . [ S.57 , 251 , 254(1) ]

Tribunal held that the entire addition of Rs. 19,58,909 made by the Assessing Officer was challenged by the assessee before the Commissioner (Appeals). The Commissioner (Appeals) had considered only 2 out of 7 items of expenditure listed by the Assessing Officer in the order of assessment. He did not consider the submissions with regard to the remaining items of expenditure. The entire issue of disallowance had to be considered afresh by the Commissioner (Appeals), after taking a holistic view of the basis of the disallowances made by the Assessing Officer and the claim of assessee that the expenses were incurred for the purpose of earning interest income. Accordingly the order of Commissioner (Appeals) was set aside and the Commissioner Appeals) was directed to decide the issue of disallowance of expenses afresh in accordance with the law.(AY.2016-17)