2025 (9) TMI 428

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....by the ld. CIT (A) as made by the ld. AO u/s 68 of the Act. 03. The facts in brief are that the assessee filed the return of income on 26.09.2018, declaring total income of Rs. 12,05,270/- which was revised on 28.02.2019 with the same income. Thereafter, the case of the assessee was selected for complete scrutiny for verification of transactions. Accordingly, statutory notices were duly served along with the questionnaire and were also served on the assessee. During the assessment proceedings, the ld. AO called upon the assessee to furnish copy of bank statement of current account no.007383800003751 with the YES Bank with narration of all debit and credit entries, which were duly furnished by the assessee. The ld. AO upon perusal of the ....

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....ned cash credit u/s 68 of the Act on the ground that assessee has been frequently changing its stand and it is nothing but own money routed through these unsecured loan and finally, added to the total income of the assessee. 04. In the appellate proceedings, the ld. CIT (A) after taking into account the contention of the assessee noted that assessee had borrowed Rs. 1,15,77,674 from four parties during F.Y. 2017-18. The ld CIT(A) in the tabulated chart furnished by the assessee, the loans were to the tune of Rs. 85,08,174/- and not to Rs. 1,15,77,674/-. The ld. CIT (A) further noted that the assessee has filed the copies of ledger accounts of the parties from the books of M/s Zenstar Dealers P. Ltd., whereas the name of the assessee comp....

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....orrigendum from the tax auditor the copy thereof is available at page no.97 of the Paper Book. However the ld. AO has added the loans taken during the year were Rs. 1,15,77,674/- plus expenses payable of Rs. 2,25,000/- plus bank charges to the tune of Rs. 5,500/-. We note that all these details qua the loans were available before the ld. AO. We further not that the loans were added under section 68 of the Act on the ground that the assessee has frequently changing its stand during the assessment proceeding. However, the facts available on records as well as filed by the assessee clearly speak the truth that these were unsecured loans taken by the assessee. We note that Navin Parwani has opening balance of Rs. 1,61,500/- and the closing bala....