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The ITAT upheld the deletion of the addition of unexplained unsecured loans under section 68, finding the assessee successfully established the identity, creditworthiness, and genuineness of the lenders, which were private limited companies with valid PANs and audited financial statements. The loans were routed through banking channels and repaid within the same assessment year, negating the presumption of unaccounted income. The issuance of notices under section 148 was held valid, having been preceded by proper recording of reasons and approval from the Pr. CIT. The revenue's appeal was dismissed, as the assessee discharged the onus regarding the loans' legitimacy and repayment, and no adverse inference was warranted. Consequently, no addition under section 68 was justified.
The ITAT upheld the deletion of the addition of unexplained unsecured loans under section 68, finding the assessee successfully established the identity, creditworthiness, and genuineness of the lenders, which were private limited companies with valid PANs and audited financial statements. The loans were routed through banking channels and repaid within the same assessment year, negating the presumption of unaccounted income. The issuance of notices under section 148 was held valid, having been preceded by proper recording of reasons and approval from the Pr. CIT. The revenue's appeal was dismissed, as the assessee discharged the onus regarding the loans' legitimacy and repayment, and no adverse inference was warranted. Consequently, no addition under section 68 was justified.
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