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0 ,l- lhrky{eh]U;kf;dlnL; ,oJa hjkBksMdeys'kt;UrHkkb]Z ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihyl-a@ITA No. 1490/JPR/2024 fu/kZkj.ko"kZ@AssessmentYear : 2018-19 Shri Rama Kant Saboo cuke The ACIT C-4A, Panchsheel Colony, Ajmer Road Vs. Circle-7 Jaipur – 302 019 Jaipur LFkk;hys[kk l-a@thvkbZvkjla-@PAN/GIR No.: AFEPS 7339K vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri Ashok Kanodia, CA jktLo dh vksjls@Revenue by: Shri Gautam Singh Choudhary, JCIT-DR lquokbZ dh rkjh[k@Date of Hearing : 16/09/2025 mn?kks"k.kk dh rkjh[k@Date of Pronouncement: 28 /10/2025 vkns'k@ORDER PER: DR. S. SEETHALAKSHMI, J.M.

This appeal filed by the assessee is directed against the order of learned Commissioner of Income Tax, National Faceless Appeal Centre, Delhi[ for short CIT(A)] dated 06.09.2024 for the assessment year 2018-19 raising therein following grounds of appeal.

‘’1. Under the facts and circumstance of the case, learned CIT(APPEALS) was not justified while confirming the assessment order passed by AD u/s 143 (3) read with section 143 (3A) and 143 (3B) of the Income Tax Act

1961

2. Under the facts and circumstance of the case learned CIT(APPEALS) was not justified while confirming the order passed by learned Assessing Officer completing the assessment on total income of RS 3,41,8722

3. Under the facts and circumstance of the case learned CIT(APPEALS) was not justified while confirming the order passed by learned Assessing Officer disallowing exchange loss difference amounting to Rs 6,91,662.00 US 57(iii) without verifying its genuineness.

4. Under the facts and circumstance of the case, learned Assessing Officer was not justified while levying interest u/s 234 D amounting to Rs

24,695/-.

2.1 Apropos grounds of appeal of the assessee, it is noticed that the ld. CIT(A) has dismissed the appeal of the assessee by confirming the action of the AO. The narration so made by the ld.CIT(A) at para 5.2.3 to 5.2.4 and 5.3 in his order is reproduced as under:-

‘’5.2.3 Having duly considered the facts on record and the appellant's submissions it is noted first of all, that the appellant is earning income from his profession as a cost account, salary income and capital gains. As seen from Revised ITR filed under IFOS he has declared interest income of Rs. 123632 and Expenses/Deductions at Rs. 943662 resulting in under IFOS at Rs. 820030/- This is set off aganst Total Income of Rs. 3769493. Whereas in the original return loss under IFOS was at Rs. 128368. Thus the loss clamed was revised upward by Rs 691662. The appellant has explained that this loss was on account of forex loss incurred on remittance of US$ to Georgia for getting Permanent residence and has claimed the same u/s 57.

In this regard, it is pertinent to note that, as per section 57 the deduction (over and above the specified deductions in the other clauses) that can be made from the income chargeable under the head "Income from other source is "any other expenditure (not being in the nature of capital expenditure) laid out or expended wholly and exclusively for the purpose of making or earning such income.’’

In the appellant's case, the facts on record show that the expenditure that was incurred was of a personal nature Le it was incurred in the course of making an application for permanent residency in Georgia. This is a purely personal expenditure and there is no connection whatsoever of such expenditure with the earning of any Income from other Sources. The crucial issue is not of genuineness of expenditure of of claim made in revised return or even of whether such income was earned or not. but of allowability of such claim of expenditure u/s 57 As clearly pointed out by the AO the expenditure was not at all expended for earning such income under the head Other Sources

5.2.4 In the case relied upon by the app