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Under section 68, an assessee initially establishes unsecured loan credits by proving creditor identity, transaction genuineness and prima facie creditworthiness. Confirmations, tax particulars, bank statements and ledger accounts showing banking-channel transactions shift the burden to the Revenue. Low lender income, cash deposits before cheques or incomplete records may warrant further inquiry but do not alone displace that evidence; continuing accounts and banking-channel repayments support genuineness. The unsecured-loan addition was therefore deleted. Employees' PF/ESI contributions are deductible only when deposited within the due date under the relevant welfare legislation; payment before the income-tax return filing due date does not cure the delay. The related disallowance was sustained.
Under section 68, an assessee initially establishes unsecured loan credits by proving creditor identity, transaction genuineness and prima facie creditworthiness. Confirmations, tax particulars, bank statements and ledger accounts showing banking-channel transactions shift the burden to the Revenue. Low lender income, cash deposits before cheques or incomplete records may warrant further inquiry but do not alone displace that evidence; continuing accounts and banking-channel repayments support genuineness. The unsecured-loan addition was therefore deleted. Employees' PF/ESI contributions are deductible only when deposited within the due date under the relevant welfare legislation; payment before the income-tax return filing due date does not cure the delay. The related disallowance was sustained.
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