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INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
Siddhartha Nautiiyal, J, Makarand V. Mahadeokar, ACJ
M/s Rudra Petroleum – Appellant
Versus
Commissioner of Income-tax (Appeals), National Faceless Appeal Centre – Respondent
| Table of Content |
|---|
| 1. facts regarding the business and tax assessments of the appellant. (Para 2) |
| 2. arguments regarding disallowances based on tds and the nature of loans. (Para 3 , 4 , 5 , 6 , 9 , 10 , 11) |
| 3. observations focusing on verification of claims and the role of previous case law. (Para 8 , 12 , 14) |
| 4. final judgment allowing appeals for further examination. (Para 15) |
आदेश/ORDER
PER MAKARAND V. MAHADEOKAR, AM:
Both these appeals have been filed by the assessee against the separate orders passed by the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “CIT(A)”] dated 30/07/2022 & 20/07/2022 for the Assessment Years (AYs) 2014-15 and 2015-16 respectively. Since the assessee is same, for the sake of convenience, both appeals are disposed of by way of this common order.
Facts of the case:
2. The assessee is engaged in the business of trading in petrol, diesel, and oil under the proprietorship concern M/s Rudra Petroleum. Additionally, he is a partner in M/s.Rudra Minerals and M/s Rudra Construction. The assessments for both the Assessment Years were completed under Section 143(3) of the Income-tax Act, 1961 [hereinafter r
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