The ITAT upheld the addition under section 68, holding that the...

The ITAT upheld the addition under section 68, holding that the assessee failed to establish the creditworthiness of the lender and the genuineness of the loan transaction. The lender's bank account was reopened without adherence to KYC norms, and the assessee did not provide essential details such as the lender's address or PAN, despite the lender becoming a shareholder. The cash deposit and immediate transfer to the assessee, coupled with the lender's non-resident status and lack of verifiable income source, undermined the claimed loan's authenticity. The tribunal affirmed the validity of the reassessment notice, noting that the reopening was based on tangible material indicating prima facie escapement of income and was sanctioned by competent authority. The assessee's contention that source of source need not be proved was rejected, as it failed to prove even the primary source of the unsecured loan.