2022 (6) TMI 1481

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....12/2019 by the ld. Dy. Commissioner of Income Tax, Central Circle-7(2), Mumbai (hereinafter referred to as ld. AO). 2. The ground No.1 raised by the assessee is challenging the validity of re-assessment was stated to be not pressed by the ld. AR for which necessary endorsement has been made by him. Accordingly, the ground No.1 is hereby dismissed as not pressed. 3. The other grounds raised by the assessee are merely challenging the confirmation of addition by the ld. CIT(A) towards unexplained cash credit u/s.68 of the Act in the sum of Rs.10,00,000/- in respect of loan received by the assessee and disallowance of interest paid on such loan. 3.1. We have heard rival submissions and perused the materials available on record. We find that ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....tax return for the year under consideration which also proved the credit worthiness. Apart from this, the ld. AO also issued notice u/s.133(6) of the Act directly to the lender seeking for confirmation of the transaction carried on with the assessee. The lender directly filed replies before the ld. AO confirming the entire transactions with the assessee. The assessee also filed confirmation of loan balances from the lender before the ld. AO. The assessee pleaded that all these evidences collectively proved all the three necessary ingredients of Section 68 of the Act. However, the ld. AO did not heed to the contentions of the assessee and proceeded to make an addition u/s.68 of the Act and consequentially disallowed the interest paid thereon....