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    <title>2026 (2) TMI 1423 - ITAT AHMEDABAD</title>
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    <description>Unsecured loans could not be added under section 68 where lender identity, creditworthiness and transaction genuineness were supported by PAN records, returns, bank statements and banking channels, and the Rule 46A objection found no adverse rebuttal; the deletion was upheld. Interest on unsecured loans was also allowed because no nexus with non-business use was established and the Revenue failed to displace the business purpose finding; the disallowance was not sustained. Employees&#039; contribution to provident fund, however, was restored as a disallowance because deduction under section 36(1)(va) depends on deposit within the statutory due date under the welfare law, not merely before return filing.</description>
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      <link>https://www.taxtmi.com/caselaws?id=469007</link>
      <description>Unsecured loans could not be added under section 68 where lender identity, creditworthiness and transaction genuineness were supported by PAN records, returns, bank statements and banking channels, and the Rule 46A objection found no adverse rebuttal; the deletion was upheld. Interest on unsecured loans was also allowed because no nexus with non-business use was established and the Revenue failed to displace the business purpose finding; the disallowance was not sustained. Employees&#039; contribution to provident fund, however, was restored as a disallowance because deduction under section 36(1)(va) depends on deposit within the statutory due date under the welfare law, not merely before return filing.</description>
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