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    <title>2026 (5) TMI 1004 - ITAT DELHI</title>
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    <description>Opening balances of unsecured loans that were brought forward from an earlier year could not be taxed as unexplained credits under section 68 for the year under review, because no fresh inflow arose during that year. Fresh loan credits were treated as explained where the assessee produced PAN, returns, confirmations, bank statements and loan agreements, and the transactions were routed through banking channels with repayments and interest servicing reflected. The documentary record established identity, genuineness and creditworthiness, and the Revenue did not rebut it with contrary evidence. The source of source requirement was held inapplicable on these facts, so the Tribunal deleted the disputed addition.</description>
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      <title>2026 (5) TMI 1004 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=791802</link>
      <description>Opening balances of unsecured loans that were brought forward from an earlier year could not be taxed as unexplained credits under section 68 for the year under review, because no fresh inflow arose during that year. Fresh loan credits were treated as explained where the assessee produced PAN, returns, confirmations, bank statements and loan agreements, and the transactions were routed through banking channels with repayments and interest servicing reflected. The documentary record established identity, genuineness and creditworthiness, and the Revenue did not rebut it with contrary evidence. The source of source requirement was held inapplicable on these facts, so the Tribunal deleted the disputed addition.</description>
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