2024 (7) TMI 1270

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....d both the parties. Case file perused. 2. The Revenue pleads the following twin substantive grounds in the instant appeal : 1. "On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of Rs.99,00,000/- made in respect of unsecured loans despite the fact that the assessee failed to prove the creditworthiness of the creditor ie. Mrs.Safiabai Rampurawala and the creditor had never filed return of income including that for the year under consideration and hence huge amount of loan given by the creditor is unexplained cash credit u/s 68 of the Income tax Act". 2. "On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of ....

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.... the said remand report filed on 24.01.2024 [pages 244-247] that he had in fact filed additional details of bank statements etc., which allegedly indicated the concerned party Smt. Safiabai Rampurawala to have received various sums from her son Shri Mustaq Ahmed Fazli Hussain [settled in Dubai]. Mr. Joshi drew strong support from the CIT(A)-NFAC findings that the impugned addition has rightly been deleted in light of the said material. 5.1. All these assessee's arguments fail to evoke our concurrence. This is for the precise reason that it had filed it's rejoinder containing additional details/evidence before the CIT(A)- NFAC which had nowhere been put to factual verification at the Assessing Officer's end during remand proceedings. The ....