ORDER

PER MANISH AGARWAL, AM :

The present appeal is filed by the revenue against the order of Ld. Commissioner of Income Tax [“Ld. CIT(A)”] National Faceless Appeal Centre (NFAC) dated 29.11.2023 in Appeal No. CIT(A), Delhi- 4/10730/2019-20 passed u/s 250 of the Income Tax Act, 1961 [“the Act”] arising out of the assessment order dated 30.12.2019 passed u/s 143(3) of the Act pertaining to Assessment Year 2017-18.

2. Brief facts of the case are that assessee is a Private Limited company and filed its return of income on 21.03.2018, declaring total income of INR 2,130/-. The assessee is a ‘Non-Banking Finance Companies’ (NBFC) and carry the business of investment in all its aspects and is dealers in shares, stock, debentures, debenture stock, bonds, obligations and units. The case was selected for Limited Scrutiny to examine the following issues:

- Expenses debited to P&L A/c for earning exempt income as per schedule BP of ITR is significantly lower as compared to investments made to earn exempt income;

- Introduction of large capital NBFC/Investment Companies.

- Low income in comparison to high loans/advances/ Investment in shares appearing in balance sheet.

3. During the year under a