https://www.taxtmi.com/caselaws?id=783670 Cash deposits during the demonetization period were treated by the AO as unexplained u/s 68. The ITAT held that the deposits were regular business collections of pre-existing loan EMIs by an RBI-registered NBFC, supported by borrower-wise recovery particulars; the non-round-figure receipts indicated inclusion of non-SBNs, deposits across multiple banks/locations showed normal operations, and the AO gave no cogent basis for attributing "own money" or for ignoring bank reporting errors. Section 269T was held inapplicable as it governs the borrower's repayment restrictions, not the lender's receipts; the s. 68 addition was deleted and the Revenue's appeal dismissed. Separately, interest paid under an OTS was held deductible u/s 43B on payment basis to avoid double taxation; the assessee's appeal was allowed. en-us Wed, 10 Dec 2025 00:00:00 +0530 Sat, 20 Dec 2025 07:45:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783670 Cash deposits during the demonetization period were treated by the AO as unexplained u/s 68. The ITAT held that the deposits were regular business collections of pre-existing loan EMIs by an RBI-registered NBFC, supported by borrower-wise recovery particulars; the non-round-figure receipts indicated inclusion of non-SBNs, deposits across multiple banks/locations showed normal operations, and the AO gave no cogent basis for attributing "own money" or for ignoring bank reporting errors. Section 269T was held inapplicable as it governs the borrower's repayment restrictions, not the lender's receipts; the s. 68 addition was deleted and the Revenue's appeal dismissed. Separately, interest paid under an OTS was held deductible u/s 43B on payment basis to avoid double taxation; the assessee's appeal was allowed. Case-Laws Income Tax Wed, 10 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783670