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    <title>2025 (7) TMI 1238 - DELHI HIGH COURT</title>
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    <description>The Delhi HC upheld the ITAT&#039;s decision dismissing the assessee&#039;s appeal regarding reopening of assessment under section 147. The case involved an unsecured interest-free loan from a company to the assessee, which the Investigation Wing flagged. The HC found merit in the assessee&#039;s argument that no search was conducted establishing the lender as an accommodation entry provider, and no statement from the lender&#039;s authorized person was recorded. However, the court noted undisputed facts: the assessee failed to explain why the entity provided an interest-free loan, departmental enquiries found the lender not operating from its registered office, section 133(6) notices were returned unserved, and the assessee couldn&#039;t establish the lender&#039;s creditworthiness or transaction genuineness. The HC concluded the AO&#039;s findings regarding failure to prove creditworthiness and genuineness were justified, dismissing the appeal.</description>
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    <pubDate>Wed, 09 Jul 2025 00:00:00 +0530</pubDate>
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      <title>2025 (7) TMI 1238 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=775170</link>
      <description>The Delhi HC upheld the ITAT&#039;s decision dismissing the assessee&#039;s appeal regarding reopening of assessment under section 147. The case involved an unsecured interest-free loan from a company to the assessee, which the Investigation Wing flagged. The HC found merit in the assessee&#039;s argument that no search was conducted establishing the lender as an accommodation entry provider, and no statement from the lender&#039;s authorized person was recorded. However, the court noted undisputed facts: the assessee failed to explain why the entity provided an interest-free loan, departmental enquiries found the lender not operating from its registered office, section 133(6) notices were returned unserved, and the assessee couldn&#039;t establish the lender&#039;s creditworthiness or transaction genuineness. The HC concluded the AO&#039;s findings regarding failure to prove creditworthiness and genuineness were justified, dismissing the appeal.</description>
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      <pubDate>Wed, 09 Jul 2025 00:00:00 +0530</pubDate>
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