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    <title>2022 (6) TMI 446 - ITAT MUMBAI</title>
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    <description>Credits arising from assignment of loans and related share allotment were examined under section 68 of the Income-tax Act, 1961. The analysis stressed that the assessee had to establish the genuineness of the transactions, the identity and creditworthiness of the creditors, and lawful consideration for the assignment arrangements. On the facts noted, the absence of convincing evidence of real consideration, commercial substance, or actual settlement, together with the financial position of the assignor entities and the surrounding circumstances, supported treatment of the credits as unexplained. Mere journal or book entries were insufficient where the explanation remained unsatisfactory, and the additions were sustained.</description>
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      <description>Credits arising from assignment of loans and related share allotment were examined under section 68 of the Income-tax Act, 1961. The analysis stressed that the assessee had to establish the genuineness of the transactions, the identity and creditworthiness of the creditors, and lawful consideration for the assignment arrangements. On the facts noted, the absence of convincing evidence of real consideration, commercial substance, or actual settlement, together with the financial position of the assignor entities and the surrounding circumstances, supported treatment of the credits as unexplained. Mere journal or book entries were insufficient where the explanation remained unsatisfactory, and the additions were sustained.</description>
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