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The ITAT dismissed Revenue's appeal regarding unsecured loans under s.68, upholding CIT(A)'s deletion of additions after verifying lenders' documentation and creditworthiness. The Tribunal noted that CIT(A) possesses co-terminus powers with the AO and had properly examined all evidence. Regarding cash found during search, the ITAT allowed the assessee's appeal, accepting that the seized cash belonged to the company where assessee worked as Finance Head, as corroborated by the company's books. The Tribunal rejected additions for alleged on-money payments for flat purchase, ruling that evidence from a third-party search couldn't be used in s.153A proceedings without initiating separate s.153C proceedings with proper satisfaction note. Interest under s.234A was confirmed as mandatory for late filing, while s.234C interest was limited to returned income only.
The ITAT dismissed Revenue's appeal regarding unsecured loans under s.68, upholding CIT(A)'s deletion of additions after verifying lenders' documentation and creditworthiness. The Tribunal noted that CIT(A) possesses co-terminus powers with the AO and had properly examined all evidence. Regarding cash found during search, the ITAT allowed the assessee's appeal, accepting that the seized cash belonged to the company where assessee worked as Finance Head, as corroborated by the company's books. The Tribunal rejected additions for alleged on-money payments for flat purchase, ruling that evidence from a third-party search couldn't be used in s.153A proceedings without initiating separate s.153C proceedings with proper satisfaction note. Interest under s.234A was confirmed as mandatory for late filing, while s.234C interest was limited to returned income only.
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