https://www.taxtmi.com/caselaws?id=465859 For addition under s. 68 relating to an unsecured loan and consequential disallowance of interest, the ITAT held that once the assessee-firm establishes the lender's identity and the transaction's genuineness through confirmations, return particulars and bank statements, its initial onus stands discharged; the Department must then prove, with positive material, that the apparent is not real. Non-response to s. 133(6) notices and the lender's low returned income were held insufficient, particularly where the loan was shown to be funded through banking channels and the assessee was not required to explain "source of source". In the absence of any finding that interest was not credited to the lender or had flowed back to the assessee, the loan and related interest were held allowable and the Revenue's appeal was dismissed. en-us Fri, 26 Apr 2024 00:00:00 +0530 Mon, 12 Jan 2026 20:43:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465859 For addition under s. 68 relating to an unsecured loan and consequential disallowance of interest, the ITAT held that once the assessee-firm establishes the lender's identity and the transaction's genuineness through confirmations, return particulars and bank statements, its initial onus stands discharged; the Department must then prove, with positive material, that the apparent is not real. Non-response to s. 133(6) notices and the lender's low returned income were held insufficient, particularly where the loan was shown to be funded through banking channels and the assessee was not required to explain "source of source". In the absence of any finding that interest was not credited to the lender or had flowed back to the assessee, the loan and related interest were held allowable and the Revenue's appeal was dismissed. Case-Laws Income Tax Fri, 26 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465859