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    <title>2026 (1) TMI 34 - ITAT DELHI</title>
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    <description>Addition under s.68 for unsecured loan turned on whether the assessee discharged the burden to prove identity, genuineness, and creditworthiness of the lender. Identity and genuineness were accepted based on tax particulars and banking-channel transactions, and creditworthiness was established from bank statements showing adequate balances and business turnover; the AO could not invoke &quot;source of source&quot; scrutiny for a non-share capital credit in AY 2018-19, and the Finance Act, 2022 proviso was inapplicable. The s.68 addition was directed to be deleted. Rejection of books under s.145(3) and GP estimation failed because no specific defects or stock discrepancies were shown and audited records were maintained; consequently, the GP addition was deleted and the appeal allowed.</description>
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    <pubDate>Fri, 19 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 34 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=784278</link>
      <description>Addition under s.68 for unsecured loan turned on whether the assessee discharged the burden to prove identity, genuineness, and creditworthiness of the lender. Identity and genuineness were accepted based on tax particulars and banking-channel transactions, and creditworthiness was established from bank statements showing adequate balances and business turnover; the AO could not invoke &quot;source of source&quot; scrutiny for a non-share capital credit in AY 2018-19, and the Finance Act, 2022 proviso was inapplicable. The s.68 addition was directed to be deleted. Rejection of books under s.145(3) and GP estimation failed because no specific defects or stock discrepancies were shown and audited records were maintained; consequently, the GP addition was deleted and the appeal allowed.</description>
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      <pubDate>Fri, 19 Dec 2025 00:00:00 +0530</pubDate>
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