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    <title>2026 (5) TMI 1627 - ITAT DELHI</title>
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    <description>Where the assessee substantiates a loan with confirmation, PAN, bank statements, NBFC registration, ITRs, audited accounts and the loan agreement, the primary onus under section 68 is discharged by showing identity, creditworthiness and genuineness, and the addition cannot be sustained on suspicion or a third-party statement alone. Since the funds moved through banking channels, the loan was repaid, and no independent material rebutted the documentary evidence or proved the transaction to be bogus, the section 68 addition was deleted. The related section 69C disallowance for interest was also deleted because the factual basis for treating the expenditure as unexplained was not established.</description>
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    <pubDate>Wed, 29 Apr 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 1627 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=792425</link>
      <description>Where the assessee substantiates a loan with confirmation, PAN, bank statements, NBFC registration, ITRs, audited accounts and the loan agreement, the primary onus under section 68 is discharged by showing identity, creditworthiness and genuineness, and the addition cannot be sustained on suspicion or a third-party statement alone. Since the funds moved through banking channels, the loan was repaid, and no independent material rebutted the documentary evidence or proved the transaction to be bogus, the section 68 addition was deleted. The related section 69C disallowance for interest was also deleted because the factual basis for treating the expenditure as unexplained was not established.</description>
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