2025 (7) TMI 1421

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....evenue : Shri Leyaqat Ali Aafaqui, Sr. AR ORDER PER SANDEEP GOSAIN, JM: The present appeal has been filed by the assessee challenging the impugned order 06.02.2025 passed u/s 250 of the Income Tax Act, 1961 ('the Act'), by the National Faceless Appeal Centre, Delhi / CIT(A), for the A.Y 2010-11. 2. All the Grounds raised by the are interrelated and interconnected and relates to challen....

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....essment proceedings assessee had filed financials, loan confirmation ledger and copy of bank statement which established that the 'source of funds' advanced by M/s. Sunshine Merchants Pvt Ltd is borrowing and security premium. Hence applying the principles of 'preponderance of probability' and keeping in view that assessee failed to discharge the burden of proof, the transaction was treated as 'un....

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....ment in the case of M/s Sunshine Merchants Private Limited was submitted but considering the financial health of M/s. Sunshine Merchants Private Limited, the additions on 'substantive basis' was made in the hands of assessee. 7. After having carefully gone through the facts and circumstances of the present case, we found that it is an undisputed fact that the present assessee had taken unsecure....