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    <title>2025 (12) TMI 1638 - ITAT DELHI</title>
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    <description>The dominant issue was whether a sum treated as unexplained money under s. 69A r/w s. 115BBE could be added solely on directors&#039; statements alleging that, out of a stated loan of Rs. 35 crore, only Rs. 10 crore was advanced by cheque and the balance Rs. 25 crore in cash. The ITAT held that the CIT(A) correctly accepted the assessee&#039;s explanation supported by a contemporaneous loan agreement and consistent NBFC lending pattern at high interest rates on which TDS had been deducted and credit allowed, and the Revenue failed to controvert the agreement&#039;s authenticity or show any infirmity in the appellate findings. The deletion of the addition was upheld and the Revenue&#039;s appeal was dismissed.</description>
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    <pubDate>Wed, 03 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1638 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=784098</link>
      <description>The dominant issue was whether a sum treated as unexplained money under s. 69A r/w s. 115BBE could be added solely on directors&#039; statements alleging that, out of a stated loan of Rs. 35 crore, only Rs. 10 crore was advanced by cheque and the balance Rs. 25 crore in cash. The ITAT held that the CIT(A) correctly accepted the assessee&#039;s explanation supported by a contemporaneous loan agreement and consistent NBFC lending pattern at high interest rates on which TDS had been deducted and credit allowed, and the Revenue failed to controvert the agreement&#039;s authenticity or show any infirmity in the appellate findings. The deletion of the addition was upheld and the Revenue&#039;s appeal was dismissed.</description>
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      <pubDate>Wed, 03 Dec 2025 00:00:00 +0530</pubDate>
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