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    <title>2025 (3) TMI 1929 - ITAT DELHI</title>
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    <description>Reassessment based only on Investigation Wing information, without independent inquiry by the AO, was treated as borrowed satisfaction and therefore unsustainable. The discussion also accepted the lender&#039;s creditworthiness and the genuineness of the loan where financial statements, business profile, advances reflected in accounts, and routing through banking channels supported the transaction; the addition was not sustained on a mere misplaced doubt about financial capacity. No Rule 46A violation was made out on the stated facts. The Revenue&#039;s challenge thus failed and the assessee&#039;s relief remained undisturbed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=469975</link>
      <description>Reassessment based only on Investigation Wing information, without independent inquiry by the AO, was treated as borrowed satisfaction and therefore unsustainable. The discussion also accepted the lender&#039;s creditworthiness and the genuineness of the loan where financial statements, business profile, advances reflected in accounts, and routing through banking channels supported the transaction; the addition was not sustained on a mere misplaced doubt about financial capacity. No Rule 46A violation was made out on the stated facts. The Revenue&#039;s challenge thus failed and the assessee&#039;s relief remained undisturbed.</description>
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