2025 (12) TMI 1042

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....nt : Shri Arun Kanti Datta-CIT DR ORDER PER SAKTIJIT DEY, VICE PRESIDENT: The captioned appeals by the department arise out of two separate orders, passed by the learned Commissioner of Income Tax (Appeals), Mumbai ('ld.CIT(A) for short), pertaining to the assessment years (A.Ys.) 2009-10 and 2010-11. Both the appeals involve common issue of deletion of additions made towards unexplained ....

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....ed unsecured loan of Rs. 22,50,000/- from M/s Meridian Gems in financial year (F.Y. for short) 2009-10, corresponding to A.Y. 2010-11. Whereas, he had availed loan from M/s Naman Exports in F.Y. 2007-08 and 2008-09, aggregating to Rs. 67,50,000/- and as on 31.03.2009, the closing balance of such loan stood at Rs. 62,23,000/-. Based on such information, the A.O. reopened the assessments u/s. 147 of....

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....ing appeals before ld. first appellate authority. 5. After considering the submissions of the assessee, in the context of facts and circumstances on record, ld. first appellate authority being convinced that the assessee has discharged the onus to prove the genuineness of the loan transaction, deleted the additions. 6. We have considered rival submissions and perused the materials available ....

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.... gone through the facts and evidences, ld. first appellate authority has observed that to prove the loan transactions, the assessee had furnished copies of bank statement, confirmation, audited accounts and balance sheet, income tax return copies of the lenders, not only before the A.O. but before ld. first appellate authority. He has further recorded a finding of fact that insofar as loan availed....