2025 (9) TMI 519

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....A KAMBLE, JUDICIAL MEMBER: This is an appeal filed against the order dated 07-07- 2023 passed by National Faceless Appeal Centre (NFAC), Delhi for assessment year 2011-12. 2. The grounds of appeal are as under:- "1. That on facts, and in law, the learned AO has grievously erred in re-opening of assessment u/s 147 of the Act. 2. That on facts, and in law, the learned NFAC-CI....

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....ural income. The Assessing Officer observed that during the year under consideration, the assessee made cash deposits amounting to Rs. 49,10,200/- in various banks during the year. The source of such cash deposits being submitted by the assessee is unsecured loans from thirty fellow villagers who lent money from their agricultural income. Out of these thirty lenders, only two lenders advanced loan....

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....T(A) to prove the identity, genuineness and creditworthiness of unsecured loan:- * Election Card of the person who have given loan * Confirmation of accounts of confirming transaction with the assessee * Form 7/12 extract which indicates that the person who has given money is farmer and capable of giving loan The Ld. AR further submitted that out of total 29 lenders f....

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....come. The ld. D.R. submitted that the matter may be remanded back to the Assessing Officer to verify regarding the payment of these amounts to the concerned lenders. 7. We have heard both the parties and perused all the relevant material available on record. From the perusal of the statements u/s. 132(4)/131/133A of the Income Tax Act, all the parties that of six parties has confirmed that the ....