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    <title>2026 (5) TMI 1128 - ITAT AHMEDABAD</title>
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    <description>Unsecured loan additions under section 68 were deleted because the assessee produced confirmations, PAN, income-tax returns, bank statements and financial records showing identity, creditworthiness and genuineness of the lenders, and the Revenue failed to rebut that primary evidence. Telescoping was also accepted for Narayani Enterprise because the cash source was linked to on-money receipts already taxed in another entity&#039;s hands, avoiding double taxation. On interest, the disallowance under section 36(1)(iii) was sustained only to the limited extent supported by the record, as the broader disallowance of diverted borrowed funds was found excessive.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791926</link>
      <description>Unsecured loan additions under section 68 were deleted because the assessee produced confirmations, PAN, income-tax returns, bank statements and financial records showing identity, creditworthiness and genuineness of the lenders, and the Revenue failed to rebut that primary evidence. Telescoping was also accepted for Narayani Enterprise because the cash source was linked to on-money receipts already taxed in another entity&#039;s hands, avoiding double taxation. On interest, the disallowance under section 36(1)(iii) was sustained only to the limited extent supported by the record, as the broader disallowance of diverted borrowed funds was found excessive.</description>
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