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    <title>2026 (1) TMI 354 - ITAT AHMEDABAD</title>
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    <description>The dominant issue was whether interest paid on unsecured loans could be disallowed as non-genuine/accommodation entries under s.37. The ITAT held that where no fresh loans were raised, interest was paid on opening loan balances with TDS deducted, and lender confirmations and return particulars were on record, disallowance cannot rest on third-party statements or unrelated material absent a demonstrated nexus or evidence of cash being routed back; consequently, the deletion of the interest disallowance was upheld. A related issue concerned addition based on third-party Tally data; as no evidence connected the taxpayer to the alleged entry provider or to the cited ledger entries, the deletion was sustained. The revenue&#039;s appeal was dismissed.</description>
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    <pubDate>Mon, 24 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 354 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=784598</link>
      <description>The dominant issue was whether interest paid on unsecured loans could be disallowed as non-genuine/accommodation entries under s.37. The ITAT held that where no fresh loans were raised, interest was paid on opening loan balances with TDS deducted, and lender confirmations and return particulars were on record, disallowance cannot rest on third-party statements or unrelated material absent a demonstrated nexus or evidence of cash being routed back; consequently, the deletion of the interest disallowance was upheld. A related issue concerned addition based on third-party Tally data; as no evidence connected the taxpayer to the alleged entry provider or to the cited ledger entries, the deletion was sustained. The revenue&#039;s appeal was dismissed.</description>
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      <pubDate>Mon, 24 Nov 2025 00:00:00 +0530</pubDate>
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