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    <title>2025 (2) TMI 816 - ITAT PUNE</title>
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    <description>The dominant issue was whether revision under s. 263 was justified on the ground that the assessment order was erroneous and prejudicial to the interests of the Revenue due to lack of enquiry into unsecured loans. The Tribunal held that the AO failed to conduct necessary verification of the lenders&#039; creditworthiness and the genuineness of the transactions, as no loan confirmations were filed, one lender had not filed a return for the relevant year, another disclosed meagre income, and the lenders lacked resources to advance large interest-free sums. The continued non-repayment without interest was found contrary to human probabilities, reinforcing non-genuineness. The s. 263 revision was upheld and the appeal was dismissed.</description>
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    <pubDate>Fri, 31 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (2) TMI 816 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=766269</link>
      <description>The dominant issue was whether revision under s. 263 was justified on the ground that the assessment order was erroneous and prejudicial to the interests of the Revenue due to lack of enquiry into unsecured loans. The Tribunal held that the AO failed to conduct necessary verification of the lenders&#039; creditworthiness and the genuineness of the transactions, as no loan confirmations were filed, one lender had not filed a return for the relevant year, another disclosed meagre income, and the lenders lacked resources to advance large interest-free sums. The continued non-repayment without interest was found contrary to human probabilities, reinforcing non-genuineness. The s. 263 revision was upheld and the appeal was dismissed.</description>
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      <pubDate>Fri, 31 Jan 2025 00:00:00 +0530</pubDate>
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