The Appellate Tribunal considered the issue of addition u/s 68...

The Appellate Tribunal considered the issue of addition u/s 68 where the income reported in the ITR was deemed too low to support a high amount advanced. The AO did not reject the books of accounts or doubt the genuineness of documents. The Tribunal found that the appellant had established the identity, creditworthiness of lenders, and genuineness of transactions through proper banking channels. The source of source for unsecured loans need not be proven. The tax audit report of the lender did not raise adverse comments. The loans were reflected in the lender's audited balance sheet, and scrutiny assessments did not draw adverse inferences. The genuineness of the transaction and creditworthiness of the lender were established, leading to a decision in favor of the assessee as the addition was deemed unsustainable.

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