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    <title>2025 (12) TMI 165 - ITAT KOLKATA</title>
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    <description>ITAT Kolkata dismissed the Revenue&#039;s appeal and upheld the CIT(A)&#039;s order in full. On the addition under s.68 for alleged bogus unsecured loans, the Tribunal held that the assessee had discharged its onus by furnishing complete documentation, demonstrating repayment, creditor responses to s.133(6) notices, and lenders&#039; financial capacity; reliance on third-party statements without cross-examination vitiated the AO&#039;s conclusion. On the addition for alleged bogus purchases, ITAT endorsed the CIT(A)&#039;s factual finding that the AO&#039;s inference was erroneous and unsupported by evidence, rendering the estimated addition unsustainable. The addition for notional interest on supposed cash loans was also deleted, as records showed only banking-channel loans with accounted interest and no violation of ss.271D/271E.</description>
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    <pubDate>Tue, 28 Oct 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 165 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=782625</link>
      <description>ITAT Kolkata dismissed the Revenue&#039;s appeal and upheld the CIT(A)&#039;s order in full. On the addition under s.68 for alleged bogus unsecured loans, the Tribunal held that the assessee had discharged its onus by furnishing complete documentation, demonstrating repayment, creditor responses to s.133(6) notices, and lenders&#039; financial capacity; reliance on third-party statements without cross-examination vitiated the AO&#039;s conclusion. On the addition for alleged bogus purchases, ITAT endorsed the CIT(A)&#039;s factual finding that the AO&#039;s inference was erroneous and unsupported by evidence, rendering the estimated addition unsustainable. The addition for notional interest on supposed cash loans was also deleted, as records showed only banking-channel loans with accounted interest and no violation of ss.271D/271E.</description>
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      <pubDate>Tue, 28 Oct 2025 00:00:00 +0530</pubDate>
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