Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
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The ITAT upheld the deletion of addition u/s 68 regarding the genuineness, creditworthiness, and transactions of loan creditors, relying on the orders of Ambe Tradecorp (P.) Ltd. [2022 (7) TMI 902 - Gujarat HC] and Sandip Kumar Gupta [2024 (7) TMI 1574 - ITAT Kolkata]. The loan amount was duly repaid during the assessment year, and the assessee was not the beneficial owner. The assessee provided evidence acknowledged by the CIT(A), ruling out contraventions of Section 68 regarding identity, creditworthiness, and banking channel transactions. The ITAT also upheld the CIT(A)'s decision on interest on the alleged unsecured loan, following the same principle laid down in the cited orders. The appeal was decided against the revenue.
The ITAT upheld the deletion of addition u/s 68 regarding the genuineness, creditworthiness, and transactions of loan creditors, relying on the orders of Ambe Tradecorp (P.) Ltd. [2022 (7) TMI 902 - Gujarat HC] and Sandip Kumar Gupta [2024 (7) TMI 1574 - ITAT Kolkata]. The loan amount was duly repaid during the assessment year, and the assessee was not the beneficial owner. The assessee provided evidence acknowledged by the CIT(A), ruling out contraventions of Section 68 regarding identity, creditworthiness, and banking channel transactions. The ITAT also upheld the CIT(A)'s decision on interest on the alleged unsecured loan, following the same principle laid down in the cited orders. The appeal was decided against the revenue.
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