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    <title>2021 (4) TMI 478 - ITAT MUMBAI</title>
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    <description>Addition under section 68 for alleged bogus unsecured loans was unsustainable because the assessee produced PAN, returns, confirmations, bank statements, audited accounts and affidavits to establish identity, creditworthiness and genuineness, and the creditors responded to notices under section 133(6). The Revenue relied mainly on investigation material and third-party statements from a tainted group, but made no independent enquiry or rebuttal and did not show movement of unaccounted cash. On these facts, the burden had shifted to the Revenue and was not discharged, so the section 68 addition was deleted and the consequential disallowance of interest on the loans also could not survive.</description>
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      <title>2021 (4) TMI 478 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=406362</link>
      <description>Addition under section 68 for alleged bogus unsecured loans was unsustainable because the assessee produced PAN, returns, confirmations, bank statements, audited accounts and affidavits to establish identity, creditworthiness and genuineness, and the creditors responded to notices under section 133(6). The Revenue relied mainly on investigation material and third-party statements from a tainted group, but made no independent enquiry or rebuttal and did not show movement of unaccounted cash. On these facts, the burden had shifted to the Revenue and was not discharged, so the section 68 addition was deleted and the consequential disallowance of interest on the loans also could not survive.</description>
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