During The Assessment Proceedings, The Assessee Produced Detailed Reconciliation Of The Return Filed Under Section 139 And Under Section 153A With Relevant Documentary Evidence Before The Assessing Officer. From The Reconciliation, The Assessing Officer Accepted The Additional Interest Income Offered Without Any Seized Documents During The Course Of Search In The Return Filed Under Section 153a But Did Not Allow The Legitimate Deduction Towards Interest Expenses Wrongly Short Claimed While Filing The Return Under Section 139 . The Assessing Officer Rejected The Claim Of Interest On Unsecured Loan. The Tribunal held that The Assessing Officer was to restrict the addition to the extent of difference between the interest income offered and the interest expenses claimed.( AY.2012-13, 2017-18)
Satya Narayan Choudhary v. A CIT (2020) 80 ITR 95( Jodh) (Trib)
S. 69 :Unexplained investments – Search and seizure – Construction activities – Retraction of statement – Addition is held to be not valid[ [S.69A 132(4) ]