आदेश / ORDER

PER MAKARAND VASANT MAHADEOKAR, AM:

This appeal filed by the assessee is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi[hereinafter referred to as "CIT(A)"], dated 23.07.2025 under section 250 of the Income Tax Act, 1961[hereinafter referred to as "the Act"], arising out of the assessment order passed by the Assessing Officer under section 143(3) read with section 147 of the Act dated 12.12.2019 for the assessment year 2012–13.

Facts of the Case

2. The facts of the case, as emanating from the assessment order, are that the assessee e-filed its return of income for A.Y. 2012–13 on 28.09.2012 declaring total income at Rs. Nil after claiming set-off of carried forward losses pertaining to A.Ys. 2004–05 and 2005–06. The case was selected for scrutiny and the original assessment was completed under section 143(3) on 17.03.2015 determining income at Rs. Nil.

3. Subsequently, on perusal of records, it was noticed by the Assessing Officer that the assessee had credited an amount of Rs. 11,03,62,194/- to its Profit and Loss Account, being principal amount of loan waived by banks. In the computation of income, how