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    <title>2020 (12) TMI 175 - ITAT MUMBAI</title>
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    <description>ITAT held that the additions u/s 68 towards unsecured loans and share application money were largely unsustainable as the assessee had discharged the primary onus by proving identity, creditworthiness of investor entities, and genuineness of transactions through bank statements and audited financials showing sufficient reserves. Revenue failed to rebut this with cogent evidence; unserved summons and third-party investigation statements not confronted to the assessee could not justify the additions. The assessee was not required to prove source of source. ITAT rejected the argument of lack of jurisdiction, holding it was a complete, not limited, scrutiny under CASS and AO was empowered to examine all issues. Appeal was partly allowed in favour of the assessee.</description>
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      <title>2020 (12) TMI 175 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=401376</link>
      <description>ITAT held that the additions u/s 68 towards unsecured loans and share application money were largely unsustainable as the assessee had discharged the primary onus by proving identity, creditworthiness of investor entities, and genuineness of transactions through bank statements and audited financials showing sufficient reserves. Revenue failed to rebut this with cogent evidence; unserved summons and third-party investigation statements not confronted to the assessee could not justify the additions. The assessee was not required to prove source of source. ITAT rejected the argument of lack of jurisdiction, holding it was a complete, not limited, scrutiny under CASS and AO was empowered to examine all issues. Appeal was partly allowed in favour of the assessee.</description>
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      <pubDate>Thu, 03 Dec 2020 00:00:00 +0530</pubDate>
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