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    <title>2026 (8) TMI 33 - ITAT MUMBAI</title>
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    <description>Unsecured loans and corresponding interest could not be treated as unexplained where the assessee produced lender confirmations, tax returns, bank statements, ledger accounts and financial statements. The material established lender identity, financial capacity and transaction genuineness, with loans routed through banking channels and interest paid after tax deduction at source. The Department did not disprove this evidence or substantiate allegations that lenders&#039; sources were non-genuine. Selective additions were also inconsistent with acceptance of most of the same loan transactions. For the relevant years, the assessee was not required to prove the source of lenders&#039; funds. The loan and interest additions were therefore deleted.</description>
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      <title>2026 (8) TMI 33 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=796160</link>
      <description>Unsecured loans and corresponding interest could not be treated as unexplained where the assessee produced lender confirmations, tax returns, bank statements, ledger accounts and financial statements. The material established lender identity, financial capacity and transaction genuineness, with loans routed through banking channels and interest paid after tax deduction at source. The Department did not disprove this evidence or substantiate allegations that lenders&#039; sources were non-genuine. Selective additions were also inconsistent with acceptance of most of the same loan transactions. For the relevant years, the assessee was not required to prove the source of lenders&#039; funds. The loan and interest additions were therefore deleted.</description>
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