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ITAT restored additions u/s 68 relating to 12 creditors where assessee failed to establish creditworthiness despite transactions through banking channels. Mere provision of PAN details and bank transactions deemed insufficient to discharge burden of proof. Banking channel transactions do not automatically validate creditworthiness u/s 68. Matter remanded to AO for fresh consideration with direction to assessee to substantiate creditworthiness of loan creditors. Restrictions u/s 269SS regarding cash loans remain applicable regardless of transaction mode. Appeal allowed for statistical purposes with opportunity for assessee to furnish additional evidence before AO.
ITAT restored additions u/s 68 relating to 12 creditors where assessee failed to establish creditworthiness despite transactions through banking channels. Mere provision of PAN details and bank transactions deemed insufficient to discharge burden of proof. Banking channel transactions do not automatically validate creditworthiness u/s 68. Matter remanded to AO for fresh consideration with direction to assessee to substantiate creditworthiness of loan creditors. Restrictions u/s 269SS regarding cash loans remain applicable regardless of transaction mode. Appeal allowed for statistical purposes with opportunity for assessee to furnish additional evidence before AO.
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