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The Appellate Tribunal addressed two key issues. Firstly, regarding the addition u/s 68, it was found that the investors' transactions were genuine, evidenced by banking records and supporting documents. The burden of proof shifted to the AO, who failed to provide evidence of wrongdoing. Some investors responded to notices, further validating the transactions. The AO's claim of cash deposits was disproven, leading to deletion of the addition. Secondly, the notional interest added lacked legal basis as the loans were interest-free and no deduction was claimed. The absence of a business connection with the borrower precluded the addition. Citing precedent, the Tribunal upheld the deletion of the notional interest addition. Ultimately, the appeal by the assessee was allowed.
The Appellate Tribunal addressed two key issues. Firstly, regarding the addition u/s 68, it was found that the investors' transactions were genuine, evidenced by banking records and supporting documents. The burden of proof shifted to the AO, who failed to provide evidence of wrongdoing. Some investors responded to notices, further validating the transactions. The AO's claim of cash deposits was disproven, leading to deletion of the addition. Secondly, the notional interest added lacked legal basis as the loans were interest-free and no deduction was claimed. The absence of a business connection with the borrower precluded the addition. Citing precedent, the Tribunal upheld the deletion of the notional interest addition. Ultimately, the appeal by the assessee was allowed.
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